Closed call for evidence

Dual marking vehicles under the GB type-approval scheme

Published 18 December 2025

Vehicle type approval in the UK

Type approval is a product certification process to ensure that new road vehicles meet the necessary safety, environmental and security requirements before they are placed on the market, registered or entered into service. Since Brexit the UK’s approval authority, the Vehicle Certification Agency (VCA), has operated a GB type approval scheme. VCA issue a manufacturer with approval for a vehicle ‘type’ once they are satisfied all the regulatory requirements are met and the manufacturer has the controls in place to ensure all production vehicles will conform.

In Northern Ireland (NI) the EU scheme continues to apply under the Windsor Framework. Vehicles sold in NI must be marked to show they have been approved by an approval authority of an EU member state. Alternatively, the VCA can issue an approval to EU requirements, known as a UKNI approval. While EU approvals can be used to sell a vehicle throughout the EU and into NI, a UKNI approval limits sale to NI and GB only.

This means that, for a vehicle to be eligible to be sold throughout the UK, it must either be approved, and marked, to both the GB and EU schemes or be marked to show it has a UKNI approval.

We understand that manufacturers are taking different approaches to the UK market. Some are approving vehicles to both the GB and EU schemes and making them available throughout the UK. Some are making the same model available throughout the UK but are marking those destined for GB with only the GB mark and those for NI with an EU mark. Some are making models that are only available to GB customers, for example they do not also have an EU approval mark so cannot be sold in NI.

This call for evidence seeks more information on the reasons behind the choices that manufacturers are making and seeks views on possible measures to ensure that in the future all vehicles are approved and marked for sale in both NI and GB.

Development of the GB type approval scheme

Provisional approval scheme

Prior to Brexit the UK was part of the EU’s type approval scheme but this ceased to apply in Great Britain from 2021. Since then, manufacturers have been required to obtain a GB approval from the VCA.

The GB type approval scheme has been phased in to give businesses and the approval authority time to prepare. From 2021, the VCA were permitted to issue GB approvals if the manufacturer could demonstrate an EU approval was in place for the relevant vehicle model. This was known as the “Provisional” type approval scheme and was intended to be a temporary, light touch approach to manage the transition to a more robust GB scheme.

The provisional scheme provided confidence that vehicles were being designed to meet the necessary technical requirements. However, it lacked some important assurance steps. For example, there was no formal check by the VCA that the manufacturer had procedures in place to ensure the conformity of all vehicles produced.

Under the provisional scheme vehicles were required to continue to carry an EU approval mark however there was no requirement for a GB approval mark. The EU mark ensured vehicles placed on the market in GB would also continue to be eligible to be sold in NI.

Full approval scheme

Legislation creating a full GB type approval scheme was introduced in December 2022 and applied to all new models launched in GB from 1 February 2024. Models already on sale before February 2024, and covered by a valid provisional approval, were permitted to continue to be produced and placed on the market. However by February 2026 all provisional approvals will have expired since they were only valid for 2 years. From February 2026 a full GB approval will be required for all existing types of passenger and commercial vehicles sold in GB. The VCA is working with manufacturers to ensure they are ready for this date.

Alignment between GB and EU schemes

The provisional scheme was fully aligned with the EU scheme since GB approvals could only be issued to manufacturers who already held a valid EU approval, and no additional requirements were required.

The full GB scheme has also been designed to ensure the technical requirements are compatible with those in the EU. This means manufacturers can design and build the same vehicles for sale in both GB and NI. This has largely been made possible because both the EU and GB schemes accept approvals harmonising with international United Nation (UN), regulations. For example, manufacturers can use the same approval to the UN regulation on vehicle braking to demonstrate compliance with the braking requirements in both the EU and GB. For subjects where international regulations are not available, we intend the GB scheme to be updated to align with requirements in the EU. So in practice, while some differences will remain, a vehicle designed to meet the requirements in the EU should fully comply with the requirements in GB.

Nonetheless, we are aware that businesses remain concerned about the possibility of divergence. To provide reassurance, the former Minister for Future Roads, Lillian Greenwood MP, committed to an ‘explicit presumption of alignment’ for the GB scheme. This commitment, in turn, means that businesses can operate on the basis that the GB scheme will be aligned with any new EU requirements

Questions

Have you been affected as a consumer or business by manufacturer decisions not to mark vehicles for sale in NI? If so give details on the impact this has had.

Has the commitment to an explicit presumption of alignment changed approaches to approving and marking vehicles for sale in GB and NI?

Type approval markings

Vehicles approved to the GB scheme must be marked with a unique GB approval number and supplied with a certificate of conformity which is the manufacturer’s declaration of compliance. For the EU market manufacturers must mark a vehicle with an EU approval number and supply an EU certificate of conformity.

Flexibility has been built into the GB scheme to assist manufacturers to “dual” mark vehicles, for example apply markings to show the vehicle is approved both for the GB and EU markets. The approval number is normally required to be placed on the statutory plate. This plate also contains the vehicle identification number (VIN), as well as some basic technical information, such as the gross vehicle weight. To avoid the need to duplicate this information, the GB scheme does not require all this information to be repeated. Instead, the GB approval number can be marked on a separate plate alongside the EU statutory plate. Alternatively, the GB number can be marked on the EU plate itself.

Questions

From your experience does the flexibility in the Great Britain scheme assist or hamper the dual marking of vehicles?

What other steps could be taken to facilitate dual marking?

Approaches to selling in the UK

While many vehicles are being approved and marked with both GB and EU approval numbers, and so can be sold throughout the UK, we are aware that some vehicles placed on the market in GB are only being marked to show their GB type approval and so cannot be sold in NI. This has the potential to disrupt businesses in NI who must instead source vehicles marked with the EU approval number.

We believe that, in many cases, vehicles marked to show compliance with the GB scheme are in fact compliant with the EU scheme, but manufacturers are choosing not to dual mark them. This is evidenced by the fact that the same vehicle model is available throughout the EU, the only apparent difference being that it is marked to show its EU approval rather than the GB approval number. This means dealers in NI cannot source new vehicles from GB and must instead order a vehicle from factories with EU approval numbers. This, in turn, can mean NI customers waiting longer to receive some vehicles despite a vehicle meeting their preferences being available in GB.

We would like to understand the reasons why manufacturers are choosing to mark vehicles as approved only for the GB when they are technically identical to those sold in the EU. Concerns about future divergence between GB and EU mandatory technical requirements may also be relevant. Manufacturers may be pre-empting an assumed future divergence in technical requirements that might prevent the vehicle type from being approved under both the GB and EU schemes.

We also believe, in a small number of cases, manufacturers have chosen to build vehicles for the GB market that do not meet the EU’s technical requirements, therefore preventing dual approval and marking. The GB scheme has been maintained to ensure that any vehicle that complies with the EU’s requirements will also meet the requirements in GB. However, the EU applies some requirements that are not yet incorporated into the GB scheme.

While vehicles meeting these additional requirements will comply with the GB scheme, some businesses may have chosen to approve vehicles in GB that lack some of the safety or environmental technologies now mandatory in the EU.

Questions

What factors are behind decisions not to dual mark vehicles?

Detail any administrative, technical, cost or other barriers.

Mandating dual marking  

As noted, the current GB regulations have been designed to facilitate businesses to mark products as approved to both the EU and GB schemes but do not currently require that they do so. Given that some manufacturers are nonetheless choosing to mark products only for the GB market we are now proposing that it should be a requirement that products are approved and marked for both the GB and EU markets to ensure they can be sold UK wide. 

This could be achieved by amending the GB type approval scheme to make it a requirement that the VCA cannot issue a GB type approval certificate unless they are satisfied the vehicle model will also be approved to the EU scheme and marked as such. This would mean that all vehicles made available on the market in GB would carry both a GB and EU approval mark and so could be sold to customers in NI. 

We would like to hear views from businesses on this approach.

Questions

Do you agree or disagree with mandating dual marking? Provide further information to support your answer.

How to respond 

See the ‘Ways to respond’ section of the call for evidence page on GOV.UK to find out how you can respond to this call for evidence.

The call for evidence period began on 18 December 2025 and will run until 12 February 2026. Ensure that your response reaches us before the closing date.

What will happen next 

We will publish a summary of responses and the government response on the homepage for this call for evidence. Paper copies will be available on request.

If you have questions about this consultation contact ivs.consult@dft.gov.uk

Full list of questions

These questions are listed here to give you an overview of what we are asking.

See the ‘Ways to respond’ section of the call for evidence page on GOV.UK to find out how you can respond to this call for evidence.

The consultation response form may include more questions, for example questions about who you are.

Have you been affected as a consumer or business by manufacturer decisions not to mark vehicles for sale in NI? If so give details on the impact this has had.

Has the commitment to an explicit presumption of alignment changed approaches to approving and marking vehicles for sale in GB and NI?

From your experience does the flexibility in the Great Britain scheme assist or hamper the dual marking of vehicles?

What other steps could be taken to facilitate dual marking?

What factors are behind decisions not to dual mark vehicles?

Detail any administrative, technical, cost or other barriers.

Do you agree or disagree with mandating dual marking? Provide further information to support your answer.

Freedom of information

Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the Freedom of Information Act 2000 (FOIA) or the Environmental Information Regulations 2004.

If you want information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a statutory code of practice with which public authorities must comply and which deals, amongst other things, with obligations of confidence.

In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information, we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the department.

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