EV Type Approval in Poland – Requirements and Procedures for Electric Cars

Last updated: 20.08.2026

Bringing electric cars to the Polish market requires selecting the appropriate type approval path and demonstrating compliance with the applicable technical and safety requirements. Depending on the chosen procedure, the manufacturer or importer must submit technical documentation, complete the required tests and obtain the documents necessary to register and place the vehicle on the market.

The type of approval affects not only the scope of regulatory obligations, but also the permitted sales volume, territorial reach, financing conditions, residual value and the possibility of registering vehicles in other EU Member States.

Electric vehicle type approval in Poland – procedures and technical paths

The introduction of electric cars, including fully electric vehicles and plug-in hybrid vehicles, to road traffic in Poland is conditional on obtaining formal technical approval.

The process of EV type approval in Poland eliminates the risk of admitting structures that do not meet strict safety standards to operation, and for EV vehicles, it includes specific tests of the high-voltage system, protection against electric shock, and battery durability.

These requirements apply both to vehicles manufactured within the EU and to Chinese electric vehicles introduced to the Polish market by an importer. They form part of the broader regulatory framework governing motor vehicles and vehicles powered by alternative fuels.

Key principle of the type approval system: responsibility for the compliance of the vehicle with requirements rests on the manufacturer or importer, not on the type approval authority. TDT verifies the documentation and test results, but it is the entity introducing the vehicle to the market that is responsible for ensuring that every unit complies with the approved type.

Three EV Type Approval Paths in Poland – Comparison

The Polish system provides three ways of admitting an electric vehicle to traffic. The choice of path determines the scope of technical obligations, sales volume, and territorial scope.

For passenger cars, it may also directly affect their future registration, resale and financing options.

The choice of procedure directly affects the profitability of the entire business project and the development of the planned distribution model. 

The full EU-WVTA path involves high expenditures for physical testing in accredited laboratories but grants full distribution freedom.

On the other hand, a national small series type approval (PL-STA) minimizes entry barriers and initial costs, but prevents legal registration of the car outside of Poland, which drastically lowers its residual value and causes banks and leasing companies to increasingly refuse financing for such vehicles.

Full EU Type Approval for Electric Cars – EU-WVTA Procedure

The procedure for a full EU type approval is multi-stage and requires the involvement of accredited technical services.

Stage 1 – Submission of an application to TDT

The application along with technical documentation is submitted by the manufacturer or its authorized representative. The documentation includes technical descriptions, drawings, simulation results, and declarations of conformity with individual legal acts. 

At this stage, TDT evaluates the completeness of the documentation and assigns the case to an appropriate technical service.

Stage 2 – Technical testing

An accredited technical service conducts physical testing of the vehicle or its systems. In the case of EVs, this includes battery tests (including durability and safety), crash tests, active safety systems (GSR2) tests, and particulate emissions (Euro 7 from 2026).

Stage 3 – Evaluation of documentation and issuance of a certificate

After positive completion of tests, TDT issues a type approval certificate. The certificate specifies the type of vehicle and the scope of approval, including a list of UN regulations and EU rules with which the vehicle complies.

Stage 4 – Issuing a Certificate of Conformity (CoC)

For each manufactured unit, the manufacturer (or importer) issues a CoC – a document confirming that a specific vehicle complies with the approved type. The CoC is necessary for vehicle registration.

Stage 5 – Post-approval surveillance

TDT conducts market surveillance – it can demand information on sold vehicles, conduct compliance audits, and order remedial actions, including a recall.

Small Series Type Approval for Electric Cars – Limits and Legal Consequences

The decision to choose a small series path creates consequences that are not always clear to dealers and buyers.

Volume limitations mean that the manufacturer/importer must strictly monitor the number of vehicles sold in a given year. Exceeding the limit established for the relevant approval path constitutes a violation of the type approval conditions. The authority may order the withdrawal of excess vehicles from circulation.

Possible exemptions from GSR2 are a technically permitted practice, but their consequence is the lack of mandatory systems like eCall (automatic emergency calling), ISA (speed assistant), or advanced AEB (advanced emergency braking). The vehicle is legally approved, but does not meet requirements that apply to vehicles with full type approval registered after July 2024.

• Consequences for the dealer: a dealer selling a vehicle with a small series approval has an obligation to inform the buyer of this fact and its practical consequences—in particular, about the inability to register abroad and the potential lack of safety systems. Neglecting this obligation can be qualified as a violation of Art. 546¹ of the Civil Code and the Consumer Rights Act.
• Consequences for financing: banks and leasing companies increasingly refuse to finance vehicles with national small series approval or demand higher deposits, taking into account the lower residual value. Importers should be aware of this problem before building a distribution model.

Role of Transportation Technical Supervision (TDT)

The sole and central state administration authority authorized to issue, refuse, and revoke vehicle type approval certificates in Poland is Transportation Technical Supervision (TDT). 

Operating on the basis of regulations on technical supervision and the Road Traffic Law, TDT coordinates the entire certification process:

• Submission of the application and evaluation of documentation: Verification of the completeness of construction documentation, drawings, and high-voltage diagrams of the vehicle.
• Technical testing: An accredited technical service conducts physical crash tests, verification of battery safety, and emissions testing for tires and brakes (in accordance with the Euro 7 standard).
• Issuance of the certificate: Following the positive completion of technical tests, the Director of TDT issues an official type approval certificate.
• Emission of certificates: On the basis of the obtained certificate, the manufacturer or importer issues an individual CoC document for each manufactured unit (VIN number).

After a vehicle is admitted to circulation, the role of TDT shifts to permanent market surveillance. The organ has the right to conduct in-service conformity checks, and in the event of detecting non-compliances that threaten safety – to order an immediate withdrawal of vehicles from the market via a recall procedure at the expense of the introducing entity.

Implementing a reliable verification is crucial, which is why it is recommended that the documentation parameters for electric vehicle certification be consulted with TDT at an early stage of the business project.

How Type Approval Affects Leasing and Financing of Electric Cars

The type of approval directly impacts the options for financing a vehicle and its residual value – which translates into the total cost of ownership.

Vehicles with full EU type approval can be freely financed by banks and leasing companies. The residual value is predictable, a secondary market exists across the entire EU, and insurers easily evaluate risks.

Vehicles with EU small series type approval (EU-STA) can be financed, but financing institutions increasingly apply elevated down-payment requirements or shortened financing periods, taking into account the risk of lower residual value and a limited secondary market.

Vehicles with national small series type approval (PL-STA) represent the most difficult case. The lack of registration options outside Poland practically eliminates the secondary market on an EU scale. Financing by main institutions is often refused or burdened with significantly worse terms.

For dealers working with corporate fleets and operational leasing, the type approval issue should be discussed with the financial institution before signing a contract with a client – avoiding a situation where financing falls through at the stage of vehicle acceptance by the bank is key to maintaining a commercial relationship.

Recall Obligations After Electric Cars Enter the Market

Type approval does not end the obligations of a manufacturer or importer. Regulation 2018/858 imposes an obligation to actively monitor vehicle compliance and react to disclosed non-compliances.

A recall procedure is launched when a manufacturer or a supervisory organ determines that a vehicle already in circulation does not meet the requirements it complied with at the time of type approval, or when a defect endangering safety appears. The obligation to report non-compliance to TDT rests on the manufacturer and importer – immediately after its discovery.

An importer who learned of a defect and failed to report it to TDT risks administrative and civil liability. In the case of an accident caused by an unreported defect, liability can be significantly broader.

A dealer not being an importer does not have a formal obligation to report non-compliances to TDT, but has an obligation to inform the importer about customer complaints that could indicate a systemic defect.

Such an obligation may arise from the distribution agreement or – if the dealer sold vehicles knowing they are non-compliant – from general provisions on tort liability.

Legal Support for Electric Vehicle Type Approval in Poland

Planning to introduce electric cars to the Polish market or assess the approval status of a specific vehicle model? Our lawyers can support manufacturers, importers and distributors in selecting the appropriate type approval path, reviewing documentation, identifying regulatory risks and coordinating the process with TDT.

Contact us to discuss the legal and regulatory requirements applicable to your project.

FAQ – EV type approval in Poland