Understand the testing and reporting needed for GSR II compliance in AİTM projects. This article examines individual and series conversions and the evidence required where a GSR II-compliant base vehicle is modified.
IMPORTANT NOTICE: Under Official Gazette No. 32799 of 31 January 2025, the GSR II implementation timetable for AİTM series-conversion, individual-conversion and installation procedures covering vehicles of categories M2, M3, N2 and N3 was postponed until 1 October 2025. Manufacturers were expected to achieve full GSR II compliance during this transitional period. Contact us for guidance on GSR II compliance.
GSR II Compliance in AİTM Conversion Projects
TSE requires vehicles undergoing individual or series conversion to demonstrate compliance with the applicable GSR II provisions.
As recorded on 2 January 2025, companies holding AİTM series-conversion approvals were temporarily unable to issue certificates of conformity, while new applications and approval extensions had also been interrupted for several procedural reasons.
Regulation (EU) 2019/2144, which became applicable in Europe on 7 July 2024 and was scheduled to become mandatory under the relevant Turkish framework from 1 January 2025, provided the basis for the GSR II approval work described here.
READ ABOUT THE NEW GSR II REQUIREMENTS FOR AİTM PROJECTS LEARN MORE
R155 Cybersecurity Reporting for Individual and Series Conversions
UN Regulation No 155 is one of the most significant reporting areas in an AİTM project. Where electrical or electronic equipment is added, the systems and components affected by the conversion require a vehicle-specific assessment, and a vehicle-specific UN R155 assessment report must be submitted. At the date stated in this article, this evidence was required for both individual and series conversions.
For category N and M vehicle conversions involving tippers, refuse vehicles, engine changes, fire appliances, concrete pumps, truck mixers, road sweepers, cranes or electrical systems, a separate assessment for each vehicle make and conversion type must be completed and documented in a report.
For changes from category N to category M such as minibus, bus and school-bus conversions, each system affecting the vehicle’s electrical/electronic architecture must undergo a threat assessment and be supported by a UN R155 assessment report.
How Can the Intelligent Speed Assistance Issue Be Resolved?
At the time described in the article, Commission Delegated Regulation (EU) 2021/1958 on intelligent speed assistance (ISA) had not been incorporated into the relevant Turkish framework, and no technical service had been appointed for that act. Reports issued by EU technical services could not be accepted directly under the applicable AİTM procedure. A clarification from the Ministry and TSE was therefore expected to provide a workable route.
Anemon Engineering has developed the technical workflow needed for these assessments and can coordinate the associated testing and reporting. Contact us for technical guidance.
Requirements When Converting an N1 or M1 Vehicle to Category M2
Vehicles converted from category N1 or M1 to category M2, typically smaller passenger vehicles based on vans, can become subject to additional requirements because the final vehicle belongs to a different category. The resulting GSR II assessment may therefore involve a substantial test and reporting programme.
Where the base-vehicle manufacturer has not included a system in the relevant approval scope, or did not need to approve it under the original category, the converter may have to provide additional testing and technical evidence.
How Is the Effect of a Conversion Assessed?
In AİTM projects, TSE may require reports for systems affected by a conversion. For some systems, technical evidence may instead demonstrate that the conversion has no adverse effect or that the approved base-vehicle condition represents the more critical case.
The TSE notice on GSR II also identifies matters that may be declared on the basis of an assessment by the authorised technical representative.
Each regulatory act contains criteria for determining whether the conversion affects the relevant vehicle system. Some systems can be assessed through components physically accessible to the converter; others would require software-level intervention. Such intervention cannot legitimately be performed without the base-vehicle manufacturer’s authorisation.
Each conversion must therefore be assessed separately against the regulations applicable to the final vehicle. Contact us for project-specific guidance.
Were Transitional Postponements Introduced?
The GSR II provisions applicable in Europe from 7 July 2024 were initially deferred to 1 January 2025 under the national framework. Because the AİTM procedures had not yet been fully clarified at the time of writing, further transitional treatment was being considered for certain requirements.
The ISA position was particularly unusual. The sector therefore expected a postponement while the relevant national rules were published and technical services with suitable TÜRKAK accreditation were appointed, allowing manufacturers to follow a recognised compliance route.
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Contact our engineering team for support with the assessment, testing and reporting required for GSR II compliance in AİTM conversion projects.
Overview
For individual and series conversions under AİTM, the applicable GSR II requirements depend on the vehicle category and the scope of the conversion. This article outlines the principal stages of testing, technical assessment and reporting. The article also covers GSR II Compliance in AİTM Conversion Projects, R155 Cybersecurity Reporting for Individual and Series Conversions and How Can the Intelligent Speed Assistance Issue Be Resolved?.
