GSR II Transition for Bodybuilders: The 7 July Deadline

The new general safety requirements due to apply from 7 July 2024 brought the GSR II transition to the forefront for bodybuilders. Manufacturers and industry associations raised concerns because thousands of vehicles could be affected. This article records the issue as it stood during the 2024 transition period and explains the potential consequences for second-stage manufacturers.

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.

Bodybuilders Faced a Standstill after 1 January 2025

Companies carrying out bodywork conversions under AİTM paused their approval programmes. Converters changing vehicles from N2 to M2 faced a requirement to submit a technical-service report under Regulation (EU) 2021/1958, although the act had not been implemented in Türkiye and no technical service had been designated for it. Manufacturers therefore called for TSE and the Ministry to establish a workable national procedure.

The GSR II Transition and Multi-Stage Vehicles

Vehicle bodywork, multi-stage approvals and conversions were also affected by the GSR II transition, creating a major challenge for the sector.

Regulation (EU) 2019/2144 was amended on 27 April 2024. For N2, N3, M2, M3, O3 and O4 vehicles, the GSR II transition date was set at 1 January 2025. Following that announcement, the sector reviewed its stock and planned to complete sales before the revised date.

At the beginning of the following week, however, distributors told dealers and bodybuilders that their existing stock had to be registered by 7 July. Subsequent discussions between bodybuilders and the authorities clarified that EU-approved vehicles were treated differently. Vehicles with EU type approval would not benefit from that national postponement.

The Postponement Applied Only to National Type Approvals

Many M2 and M3 bus manufacturers are export-oriented and therefore obtain type approvals from EU approval authorities. Manufacturers focused on the Turkish market, by contrast, generally use AİTM series-conversion or individual-vehicle approval procedures.

The postponement was reported to apply only where both the base vehicle and the second-stage vehicle held national type approvals.

Bodybuilders and other manufacturers generally follow the Turkish rules governing vehicle registration. The applicable framework includes AİTM, Regulation (EU) 2018/858, Regulation (EU) 2019/2144 and the Turkish Highway Traffic Regulation. These instruments, together with their implementing notices, determine the rules used to register a type-approved vehicle in Türkiye.

According to the information available at the time, the 7 July GSR II transition would follow the legislation under which the type approval had been issued. Manufacturers using EU type approvals would therefore have to apply the dates in Regulation (EU) 2019/2144.

The 7 July GSR II Deadline Created Urgency in the Commercial-Vehicle Sector

Distributors advised that vehicles unable to obtain end-of-series permission had to be registered by 6 July. Commercial-vehicle stocks included a substantial number of vehicles with EU, or “e”-marked, type approval.

Industry representatives reported that the issue could affect thousands of vehicles.

Manufacturers asked the Ministry to apply Article 86(3) of Regulation (EU) 2018/858 and postpone the GSR II transition for one year without distinguishing between EU and national type approvals.

Why Did Multi-Stage Vehicles Face a Particular Problem?

The European Union and other export markets requested stock information from manufacturers and provided transitional permissions for identified vehicles. Exporters were therefore able to notify the relevant authorities and obtain permission for vehicles affected by the GSR II changeover.

In multi-stage manufacture, the second-stage work depends on the systems and approvals supplied with the base vehicle. At the time, manufacturers were only beginning to understand which GSR II systems would be present on each base-vehicle configuration. They therefore had to investigate additional equipment, component supply, test planning and approval routes.

The available research indicated that complete solutions for bodybuilders were not yet established and that the approval of emerging solutions could take between six months and one year.

Consequently, by 7 July 2024 many manufacturers in Türkiye did not yet have access to the equipment, testing and approval routes needed either for existing stock or for newly supplied GSR II-compliant base vehicles.

Manufacturers therefore needed to extend their type-approval scope and establish a vehicle-specific process based on which safety systems were present, absent or affected by the second-stage work.

Affected vehicle groups included minibuses and buses, motor caravans, ambulances and truck-based special-purpose or bodywork vehicles.

Questions and Answers on the 7 July GSR II Transition for Multi-Stage Vehicles

By What Date Did Multi-Stage Vehicles Have to Be Registered?

Vehicles in categories M2, M3, N2, N3, O3 and O4 that did not comply with GSR II had to be registered by 6 July 2024.

Could Nationally Approved Vehicles Still Be Registered?

For the relevant categories, registration could continue until 1 January 2025 where both the base vehicle and the second-stage approval were national approvals under AİTM or the Turkish implementation of Regulation (EU) 2018/858.

How Were EU-Approved Vehicles to Be Registered during the GSR II Transition?

In multi-stage manufacture, for a base vehicle and second-stage vehicle with EU type approval and an “e” approval mark, 6 July 2024 was the final registration date.
Where the base vehicle had EU type approval, identified by an “e” approval mark, but the completed vehicle used a national second-stage approval, registration still had to be completed by 6 July 2024.
Vehicles already registered were not affected.

What Was the Position for End-of-Series Vehicles?

Base-vehicle manufacturers could seek Ministry permission for an end-of-series quantity equivalent to 30% of the registrations recorded in the previous calendar year. Approved vehicles could be processed for one further year. Vehicles exceeding that limit and excluded from the list remained subject to the transition conditions described above.

Summary

The GSR II transition directly affected bodybuilders because the base-vehicle approval and second-stage approval had to be assessed together. This article examines the registration and approval issues that arose during the 2024 transition period. The article also covers Bodybuilders Faced a Standstill after 1 January 2025, The GSR II Transition and Multi-Stage Vehicles and The Postponement Applied Only to National Type Approvals.