According to the draft Circular replacing Circular 47/2024, vehicles exempt from initial inspection include motor vehicles (excluding motorcycles and mopeds) and unused specialized motorbikes. These vehicles must have a period of less than two years from their manufacturing year to the application year and must be registered and licensed. Cases not eligible for exemption include modified vehicles or those lacking data in the Vietnam Register's technical safety and environmental quality certification system.

In its feedback on the draft Circular, Thanh Cong Group, a distributor of passenger car brands such as Hyundai and Skoda, and commercial vehicles under the Hyundai and TC Motor brands, proposed expanding the inspection exemption. This expansion would cover vehicles with changes made by the manufacturer or its authorized representative. A condition for this exemption is that these changes must be part of optional packages or genuine accessories declared by the manufacturer to the vehicle inspection agency. The company would be responsible for providing complete technical documentation related to these changes upon request from the management agency.

Thanh Cong's proposal primarily suits commercial vehicles, especially buses and coaches. These vehicles are often modified internally to offer more luxury, wider seats, and enhanced comfort features. Historically, customers purchasing such vehicles would opt for external facilities for modifications, subsequently needing to register these alterations with inspection authorities. With Thanh Cong's new proposal, the car manufacturer would perform modifications directly, thereby exempting buyers from re-inspection.

Each vehicle model typically offers only a few fixed versions, which often limits customer choice for suitable configurations. This situation frequently leads to the installation of external accessories, which can pose safety risks and complicate management efforts.

Vehicle inspection in Hanoi. Photo: Pham Chieu.

According to the group, allowing manufacturers to offer genuine optional packages from the outset would provide buyers more flexible choices. This approach would also assure quality, as the manufacturer would be directly responsible. This mechanism encourages the use of genuine components, contributing to improved road safety.

From a management perspective, the proposal is expected to maintain effective oversight. Manufacturers would be required to declare their accessory and optional package lists and provide documentation proving the safety and compatibility of these additions. Management agencies could then conduct post-inspections or random checks as needed.

The company proposes that only components and accessories on the declared list should qualify for exemption. Changes made outside this pre-approved list would still be subject to standard modification procedures.

This mechanism would also ease the burden on vehicle inspection centers when processing vehicle dossiers. They would only need to cross-reference the manufacturer's declared list, eliminating the need for re-inspection since all components, parts, and accessories would have been declared and assessed previously.

Regarding this content, the drafting committee has indicated that it will incorporate this proposal into the initial inspection exemption process, making necessary adjustments to the draft.

Many countries currently employ similar mechanisms. In the European Union, the Whole Vehicle Type Approval system permits manufacturers to approve a vehicle model with various versions and variants, provided these configurations are within the approved list. A vehicle can leave the factory with different configurations for wheels, tires, spoilers, or suspension without being classified as a post-sale modified vehicle.

In the United States, manufacturers self-certify all vehicle configurations, including optional packages and genuine accessories, to ensure compliance with federal safety standards. Users or dealers can install these accessories without them being considered unauthorized structural changes.

In Japan, the "Designated Parts" system exempts certain standard-compliant components and accessories from modification procedures. This exemption is granted because their safety and compatibility have been pre-assessed.

Anh Duy