Consultation outcome

Amending the UK trailer registration scheme

Updated 12 October 2023

Foreword

The UK launched a Trailer registration scheme in November 2018 as part of the requirements to ratify the 1968 Vienna Convention.

This consultation outlines our plans to amend the current trailer registration system. The changes we are proposing are technical and are principally to address specific, unintended anomalies in the way the scheme operates, that have been identified since its implementation.

We are seeking to ensure that changes work as efficiently as possible for the haulage industry and others who have registered a trailer in the scheme.

We value responses to this consultation. They will help inform our final proposals before we introduce the regulations to amend the scheme. We encourage you to reflect on the proposals set out in this consultation and to respond to the questions included in detail.

Executive summary

Introduction

As part of the preparations to ratify the 1968 Vienna Convention on Road Traffic, the UK introduced a trailer registration scheme through the Haulage Permits and Trailer Registration Act 2018, and the Trailer Registration Regulations 2018 (the 2018 regulations).

The 2018 regulations established a registration scheme for trailers and provided for registration applications, the issue of registration documents, the display of registration marks and other related matters.

We are now in a position where we need to make some minor changes to the regulations to ensure the continued smooth running of the registration scheme in the long term. The proposed changes are mostly technical in nature and are designed to improve current arrangements and address anomalies that have been identified in the current regulations.

The trailer regulations came into force on 20 November 2018. As a result, registration became mandatory on 28 March 2019 for certain UK trailers travelling in countries that have ratified the 1968 Vienna Convention on Road Traffic. This applies to all:

• commercial use trailers that weigh over 750kg in gross weight
• non-commercial trailers that weigh over 3,500kg in gross weight

Currently, the Driver and Vehicle Licensing Agency (DVLA) holds records relating to around25,500 registered trailers that are used outside of the UK in countries that are also party to the 1968 Vienna Convention on Road Transport.

There is no domestic scheme. Trailers used solely in the UK do not need to be registered. However, trailers that weigh over 750kg in gross weight can be registered on a voluntary basis even if they are not travelling abroad. Any trailers with a gross weight of 750kg or less cannot be registered with the scheme.

The main purpose of the trailer registration scheme is to assist UK hauliers in travelling unhindered abroad and to meet the requirements of the 1968 convention. Therefore, the mandatory information we collect at the point of registration is limited to that required to meet this purpose.

The information we currently hold for each registered trailer is:

• name of registered keeper
• address of registered keeper
• trailer manufacturer
• vehicle identification number (VIN) or chassis number
• maximum permissible mass (kg)
• unladen mass (kg)
• date of first registration with DVLA

Once a trailer is registered, the DVLA assigns a trailer registration number, which must be displayed on the trailer in the form of a permanently affixed plate. The keeper is also provided with a UK trailer registration certificate, which can be presented to the foreign authorities for inspection upon request.

As part of this consultation, we are proposing to amend the current legislation to also record the type of trailer being registered, for example, curtain-sided, flat bed, refrigerated and so on. This will help to more closely match the trailer with its registration documents and is consistent with the approach taken with other types of vehicle. We will ask keepers of trailers already registered as part of the scheme to update the records associated with their trailers.

We also plan to amend the regulations to clarify that vehicles registered with DVLA through the vehicle registration database cannot also be registered as part of this trailer registration scheme. This change is being made, as a small number of dual-registered vehicles have been identified and we need to clarify this point.

The proposed amendments will retain the wider framework of the current arrangements for the trailer registration service. The amendments will ensure that the legislation operates effectively but, as there are no fundamental changes to the current scheme, it will not subject businesses or individuals to any additional costs or burdens.

Proposed legislative amendments to the trailer registration scheme

This is a joint consultation between the Department for Transport (DfT) and DVLA, relating to proposed legislative amendments of the Trailer Registration Regulations 2018.

Amendments 1 to 4 are those for which DVLA is principally responsible. Amendments 5 and 6 are the responsibility of DfT.

As we intend to bring these amendments into the regulations at the same time, we have decided to undertake a combined consultation. This is to streamline the process of gathering the views of all those who may have an interest in trailer registration whether from the perspective of industry or a private individual. The amendments fall under the following topics:

We would welcome suggestions of alternative methods that you believe may achieve the stated objectives.

We would also like you to highlight any possible unintended consequences of the proposed changes, especially in terms of practical enforcement or implementation issues, which you believe are relevant.

Amendment 1: prescribed font

It is a requirement that a registered trailer must display a registration plate bearing the registration mark that has been assigned to it. The font that must be used on the registration plate is specified in the regulations.

Following implementation of the scheme, Registered Number Plate Suppliers (RNPS) advised us that their computer font package did not have the exact font as shown in the regulations. The regulations prescribe the use of the Charles Wright font.

However, the font that is readily available to the RNPS is that prescribed in the Road Vehicles (Display of Registration Marks) Regulations 2001 (Display Regulations). This is an adapted version of the Charles Wright font, which has been amended slightly to make it more effective for Automated Number Plate Readers, for example. There are slight variations in some of the characters and the software to be able to match precisely to the Charles Wright font is not readily available.

As an interim measure, we advised suppliers that it was acceptable to continue using the existing font in their software package, that is, the adapted version of the Charles Wright font. We agreed to rectify the font described in the Trailer Regulations as soon as the opportunity arose.

Therefore, we now propose amending the trailer regulations to specify the Charles Wright font as it appears in the display regulations. However, we want to ensure that customers are not disadvantaged if they have already been able to obtain trailer plates in the Charles Wright font as is currently shown in the trailer regulations.

To achieve this, we will be amending the regulations to specify that the characters of the registration mark must be either in the prescribed font or in a style that is ‘substantially similar’. Regulation 15 of the display regulations sets out the types of font that would prevent a number plate from being recognised as ‘substantially similar’.

Question 1: To what extent do you agree or disagree with the proposal to change the font used for trailer registration plates?  

Amendment 2: location of trailer inspection

The trailer regulations currently allow an examiner to inspect a trailer to determine whether it is registered and to confirm the accuracy of the details recorded in the register or shown on a registration document.

The regulations specify that an inspection can only be carried out at a designated vehicle testing station provided by the Secretary of State for Transport in Great Britain or the Department for Infrastructure in Northern Ireland. This is because the regulations were originally drafted to allow the DVSA to carry out inspection of trailers for registration purposes. However, the DVSA is unable to take up responsibility for carrying out the inspections.

The vehicle inspection contract does not currently cover trailer inspections. Due to the very low number of referrals anticipated, in combination with the need for formal inspection sites to accommodate large trailers, it is not justifiable to seek to amend this contract to add fixed sites.

Removing the need for the inspection to be carried out at a designated testing station will allow more flexibility for DVLA to delegate inspections to:

• an alternative provider if future demand required it

or

• to use sites that are not designated testing stations if the level of inspections remains very low

We are, therefore, proposing to replace the requirement in the trailer regulations for inspections at a ‘designated testing station’ with wording that will allow for the inspection to take place at an agreed location, provided that it ‘appears convenient to the Secretary of State’.

We anticipate that this change will allow an inspection provider and customers to have more flexibility in terms of agreeing the location of the inspection, provided that the inspection can be carried out in the required manner.

Question 2: To what extent do you agree or disagree with the proposal to change the place of inspection from a ‘designated testing station’ to ‘an agreed convenient place for customers and the inspection provider’?

Amendment 3: abolition of the further inspection fee following an appeal

After an inspection, the Secretary of State can refuse to register a trailer or withdraw its registration. In these circumstances, the trailer regulations allow the trailer keeper to request a further inspection. A further inspection incurs a £39 fee.

We want to amend the regulations to allow a customer to appeal a decision without a fee being required. The fee was designed to cover costs and to mirror the process in similar regulations relating to vehicle inspections. It was initially the intention that the DVSA would incorporate the inspections role into their business practices.

However, as explained, this is no longer the intention. The DVLA does not have a process in place to facilitate the collection of this fee and the anticipated number of inspection appeals is too low to justify the costs of implementing the technical solution that would be required.

Question 3: To what extent do you agree or disagree with the proposal to remove the fee associated with appeals?

Amendment 4: renewal of documents

A trailer registration is valid for 10 years, after which time it must be renewed if a trailer is going to continue to be used outside of the UK in a country that is also party to the 1968 Vienna Convention on Road Transport.

The regulations currently allow a trailer keeper to apply to renew their registration document up to 1 year before it expires, or at any time after expiry.

It is our intention to reduce the maximum period before expiry in which a keeper can apply for a renewed document to 6 months. Once requested, a renewal certificate can usually be issued within 5 days. Therefore, a 6-month renewal window would easily allow enough time for applications to be made and the certificate issued.

As the scheme was launched in 2019, the certificates issued will begin to expire in 2029. Making this change now means there is sufficient time to ensure that registered keepers can be made aware of the new requirements.

A renewal process is being developed that will issue a reminder to the keeper at 6 months before the expiry, then 3 months prior and finally 1 month if it has not been renewed. The DVLA will also issue a notification to the keeper if the certificate has expired to warn that the trailer should no longer be travelling abroad. We consider this sufficient notification to enable keepers to act if they need to.

Question 4: To what extent do you agree or disagree with the proposal to reduce the period of time associated with the renewal of trailer registration documentation?

Amendment 5: recording trailer type information

Currently, the DVLA holds records relating to around 25,500 registered trailers that are used outside of the UK in countries that are also party to the 1968 Vienna Convention on Road Transport.

The regulations set out the information that is to be collected as part of the trailer registration scheme. This includes the name and address of the registered keeper, information on the manufacturer and a VIN or chassis number. To this we intend to add details of the trailer type, for example, whether the trailer is a curtain-sided, flat bed or refrigerated. This is consistent with the approach taken for the registration of other types of vehicle. This improved link between the registration and the trailer will also help when trailer registration information is used for the purposes of detecting crimes such as goods or people smuggling.

We view this change as minor and, as such, we do not believe it will place an undue or onerous burden on the keepers of currently registered trailers and should not detract from the light-touch approach the UK has taken in relation to the trailer registration scheme.

We will work with DVLA and DVSA to develop a list of trailer types to cover all those currently registered on the scheme on both a mandatory and a voluntary basis to ensure consistency of data collection.

So information held in the DVLA trailer registration database is as accurate as possible, information on the type of trailer will be required:

• at first registration
• where the information that relates to that trailer is being amended, for example, when the trailer is bought or sold
• if the details of the keeper change for another reason

This change will apply to all trailers registered on the scheme whether that is on a mandatory or voluntary basis.

Outside of this formal update process, DVLA will also contact existing registered keepers to request that they access and update the new field on the trailer registration system.

Question 5: To what extent do you agree or disagree with the proposal to change the information collected as part of the registration process?

Amendment 6: clarifying that motor vehicles cannot be registered as trailers under HPTR

We are proposing to amend the trailer registration regulations to make it explicit that mechanically propelled vehicles cannot also be registered under the trailer registration scheme.

The change is designed to clarify the situation in relation to an A-Frame and similar towing devices, used in combination with mechanically propelled vehicles, typically small cars that are towed behind a larger vehicle such as a motorhome. The combination of an A-Frame and a motor vehicle does not constitute a trailer for the purposes of these regulations and therefore cannot be registered under HPTR.

An A-Frame and similar towing devices on their own weigh less than 750kg and are not in themselves trailers. As a result, they do not qualify to be included on the trailer registration database.

Where this type of towing device is identified as having been inappropriately registered as a trailer, DVLA will cancel the registration.

Question 6: To what extent do you agree or disagree with this proposed change to clarify that a motor vehicle cannot also be registered as a trailer?

Annex A: impact assessment

DfT has not published an impact assessment as the qualifying direct impacts on business are deemed to be under £5 million per year. Further guidance on qualifying impacts on business can be found in Section 22 of the Small Business, Employment and Enterprise Act (2015) and the Better regulation framework guidance.

As part of your response, you may suggest any alternative methods for reaching the objective and highlight any possible unintended consequences of the policy and practical enforcement or implementation issues.

How to respond

The consultation closed on 2 July 2021.