Closed consultation

Incorporating international rules into GB type approval for road vehicles

Published 4 November 2024

Applies to England, Scotland and Wales

Introduction

Motor vehicles are required to be type-approved before they go on sale. Type approval is the process whereby manufacturers of a new model of motor vehicle or trailer are required to:

• test prototypes against a range of safety and environmental standards
• obtain approval from a government body prior to placing it on sale

Type approval ensures that manufacturers are producing vehicles that comply with the safety and environmental obligations set out in legislation.

During the United Kingdom’s (UK) membership of the European Union (EU), the procedures for approving most road vehicles, and their parts before they could be sold or registered, were set out in a number of EU regulatory frameworks known as type-approval frameworks.

Now that the UK has left the EU, we have the freedom to create a system that meets the needs of manufacturers and consumers in the UK.

We’ve already made progress and established the foundations to develop our approach to vehicle regulation. The GB type approval scheme is the new automotive regulatory scheme for road vehicles in Great Britain.

The scheme was made through a statutory instrument and entered into force in January 2023. It replaces the existing provisional scheme that has been in place since Brexit, beginning with new models brought to market in February 2024. The aim of the scheme is to provide continuity and minimise costs for vehicle manufacturers. Our intention is to build on this and introduce approval frameworks for other vehicle categories in the future.

The Vehicle Certification Agency (VCA) is the sole type approval authority of the scheme and is empowered to issue the new GB type approvals in accordance with the amended provisions.

In the last few years, there have been developments in vehicle regulations in the EU and through the United Nations Economic Commission for Europe Regulations (UNECE).

We are committed to using international standards wherever possible and adopting a flexible approach to recognising other national standards and testing. To deliver this, we need to make updates to domestic regulation to recognise or mandate new standards developed internationally within the GB type approval scheme.

One example of how we are delivering this commitment is demonstrated by our recent statutory instrument that updated the GB type approval scheme for road vehicles. This legislation was laid on the 15 February 2024 and came into force on 7 March 2024. Changes included:

• permitting Euro 6e emissions standards (via UN type approvals) for cars and light goods vehicles as an alternative to the current Euro 6d requirement
• accepting certain other UN safety and environmental standards
• revising the requirements for registration plate space to align with those applied in the EU

We are now considering whether to incorporate further developments in vehicle regulations into the GB scheme, outlined by this consultation.

Purpose of consultation

This consultation considers a number of developments in vehicle regulations within the EU and internationally and asks for views on our intended approach to incorporate these into the GB scheme.

These updates will be introduced through statutory instruments to amend the assimilated regulations. In this document, “assimilated regulations” refers to the GB version of EU regulations that were retained in domestic law after Brexit and have since been amended to establish the GB type approval scheme.

This consultation covers 2 sets of proposals.

1. A group of priority proposals, where we intend to make regulations through a statutory instrument as soon as possible after the consultation.

2. A number of areas where we would like to gather views now with a view to taking them forward within a future statutory instrument on a slower timescale.

Priority proposals

Emergency Call (eCall)

Emergency Call (eCall) is a safety system which automatically provides information to the emergency services and opens a voice link from the emergency services to the vehicle if there is a collision of sufficient severity to deploy the airbags.

The system is intended to improve injury outcomes by reducing the response time by emergency services in the event of a serious collision. It offers the greatest benefit in single vehicle collisions in remote rural areas, where the collision is unlikely to be discovered and where there is a mobile phone signal. 

Since 31 March 2018, regulations have required new types of M1 (passenger cars) and N1 (light goods vehicles including pickup trucks, vans) vehicles to be equipped with eCall systems that communicate using 2G/3G mobile networks.

2G/3G networks are being phased out by mobile operators no later than 2033, meaning that eCall systems fitted to vehicles will not function and motorists will not benefit from this system in the event of a collision. 

The EU has updated its standards (via Regulation (EU) 2024/1180) so that in the future 4G/5G technology will be fitted to EU-approved vehicles.  To facilitate dual access to both the UK internal market and the EU single market, Northern Ireland (NI) continues to apply certain EU rules in relation to type approval. Accordingly, the changes apply in NI, subject to the democratic scrutiny mechanisms provided for in the Windsor Framework.

The EU regulation permits cars and light goods vehicles fitted with 4G/5G communication technology to be approved from 1 January 2025 and prevents registration of vehicles fitted with 2G/3G eCall from 1 January 2027, subject to end of series derogations. Our intended timing aligns with the EU timing.

Unless existing GB type approval regulations are amended, eCall technical requirements will continue to be based solely on 2G/3G network provisions. Therefore, vehicle manufacturers would be obliged to fit eCall systems which are not compatible with the 4G/5G services in Great Britain.

Adopting similar amendments in GB to those within Regulation (EU) 2024/1180 on eCall would:

• avoid regulatory divergence
• ease the burden on manufacturers by permitting them to develop harmonised solutions for both the UK and EU

Therefore, we propose to align our regulations with those standards that manufacturers will be required to follow to comply with developments in vehicle regulation in the EU. This will update the GB regulation to specify 4G/5G.

UN regulations also allow for the approval of eCall systems, UNECE Regulation 144. Vehicle approvals to this regulation are not currently accepted since certain important elements on privacy, data protection and personal data processing are not included at the vehicle level. However, we are considering accepting component approvals to UNECE R144 in the GB scheme.

We expect this will assist vehicle manufacturers who would be able to use these UN component approvals when seeking to obtain GB eCall approval for their vehicles. By requiring the vehicle manufacturer to continue to obtain GB approval we can ensure that the relevant privacy and data protection measures continue to be met.

End of series derogations - eCall

When new legislation comes into force, the type approval framework has provisions to allow manufacturers to apply for a derogation (or exemption) to register certain vehicles that do not comply with the incoming standards. These are known as “end of series derogations” and are intended to give manufacturers additional time to sell off any vehicle stocks made to the previous standards.

Previous practice has been to consider whether to authorise the VCA to accept applications for end of series derogations close to the point in time when it would no longer be possible to register non-compliant vehicles.

We are considering whether to make the decision to authorise VCA to accept applications when the legislation itself is laid. This will give manufacturers greater certainty when managing vehicle stocks. The applications process will remain unchanged. Manufacturers will need to satisfy the VCA that there were valid reasons why the non-compliant stock could not be sold off before the regulatory changes apply.

Windscreen wash and demist systems

GB type approval requires vehicles to be designed to meet requirements on the performance of their windscreen wash systems and windscreen demist systems. These are set out in assimilated regulations (EU) 1008/2010 and 672/2010 respectively. These procedures ensure that vehicles are designed to clear the windscreen of dirt and ice outside, and mist inside, maintaining vision in all weather conditions for the driver.

The EU has recently amended the test procedures in their equivalent regulation, Regulation (EU) 2024/883, providing a more efficient sequence of the activities in the test chamber and flexibilities in the choice of the degreaser used in the test, while ensuring better health and working conditions for the persons performing the tests.

After reviewing these changes, we have concluded that a vehicle tested to the EU requirements would perform the same as one tested on the current GB procedure.

We therefore propose aligning the test procedures in the GB scheme with those in the amended EU scheme, which in general provides more flexibility for manufacturers.

The new procedures would be applicable from the date of entry into force of the new regulation, but there would not be a requirement for tests already conducted to the old procedures to be repeated for vehicles already on sale.

HGV CO2 calculation: Vehicle Energy Consumption Calculation Tool (VECTO)

The GB type approval scheme sets out the procedure for determining a heavy-duty vehicle’s fuel consumption, and therefore its carbon dioxide emissions, in assimilated Regulation (EU) 2017/2400.

As part of this regulation, the Vehicle Energy Consumption Calculation Tool (VECTO), a computer-assisted simulation program, is specified to enable manufacturers to calculate a vehicle’s fuel and CO2 emissions.

As of 1 January 2019, all new goods vehicles sold with a gross vehicle weight of over 7500kg, must come with a certified CO2 and fuel consumption declaration, created by VECTO.

Under the GB type approval regime, there is currently a waiver until 31 December 2026 allowing the original equipment manufacturers/suppliers to use components (such as engine, axle, gearbox, cab) that are certified to the EU version of 2017/2400, rather than the GB version, when calculating CO2 emissions for HGVs. This means that manufacturers do not have to apply for GB certification for numerous components.

Following a review of the current waiver, we have concluded that introducing a GB equivalent would likely be prohibitively costly to develop and provide no additional benefits at this time. We are therefore proposing to extend the waiver indefinitely, leaving the option open to introduce a GB system in the future if the EU system is no longer compatible with the GB type approval system. 

UNECE regulations

United Nations Economic Commission for Europe (UNECE) regulations cover around 75% to 80% of subject areas for passenger vehicles in the GB type approval scheme.

The UK is a contracting party to the UNECE’s 1958 Agreement, Revision 3. This is an international agreement relating to reciprocal recognition of vehicle approvals.

Governments (contracting parties) that sign up to an internationally agreed specification (UNECE regulation) are permitted to issue approvals to vehicles or components that comply with that regulation. Contracting parties must accept vehicles and components type-approved by another contracting party against a UNECE regulation that they are a signatory to.

The benefits of international harmonisation include reducing the complexity faced by manufacturers in attempting to understand and test vehicles to numerous national standards, and gives rise to economies of scale in manufacture, thus lowering costs.

We are proposing to update domestic legislation to ensure that the GB type approval scheme accepts UNECE regulations that the UK has signed, and thus indicated that it will accept, for subjects that currently form part of the GB type approval scheme. This includes the following UNECE regulations:

Subject	UN Regulation number(s)
ISOFIX (child safety seat attachments)	145
Automated lane keeping systems	157

Further detail on each of the proposed changes is provided below.

ISOFIX

ISOFIX is the international standard for attachment points for child safety seats in passenger cars. The relevant legislation for this requirement in the GB scheme is contained within UN Regulation 14 on safety belt anchorages.

Since the introduction of the GB scheme, the UN has updated regulation UN Regulation 14 to remove the ISOFIX requirements and move them to a new regulation, UN R145.

While approvals to UN Regulation 14 (specifically, 14.07) continue to cover ISOFIX, those to the latest series of amendments, UN Regulation 14.08, do not. This is illustrated below:

	UN Regulation 14.07 approval applies?	UN Regulation 14.08 approval applies?	UN Regulation 145 approval applies?
Safety belt anchorages	Yes	Yes	No
ISOFIX	Yes	No	Yes

We therefore propose clarifying the GB regulations such that manufacturers must approve vehicles to either UN Regulation 14.07 or to both UN Regulation 14.08 and UN Regulation 145 to remove any uncertainty and make sure it is clear that the vehicle must comply with both the safety belt anchorage requirements and those for ISOFIX.

Automated lane keeping systems (ALKS)

UN Regulation 157 provides the first internationally agreed technical requirements for an automated driving system that doesn’t require driver supervision on motorways – automated lane keeping systems (ALKS).

Vehicles approved to UN Regulation 157 will be able to control the lateral and longitudinal movements of the vehicle for extended periods without the need for further driver input or monitoring of the road.

The UN Regulation 157 was first adopted in June 2020, starting the process to allow vehicles fitted with automated driving systems to come to market. ALKS is an important first step towards the development of systems with higher levels of autonomy and broader operational design domains. Operational design domains define the operating conditions under which a vehicle’s automated driving systems can be safely engaged.

Automated vehicle technologies are set to play a major role in the transport revolution happening today across the UK, helping to improve transport across the nations by making everyday journeys safer, more convenient and more reliable. The Highway Code and UK legislation have already been amended to support full and safe use of these technologies. However, the GB type approval scheme doesn’t account for this new regulation.

We therefore propose adding UN Regulation 157 into the GB type approval scheme to enable this technology to enter the market as it becomes available.

We have previously indicated that implementing ALKS may be accompanied by measures around the recording and availability of data produced by the data storage system for automated driving (DSSAD) required for ALKS equipped vehicles. There are no plans to make such measures as part of this work, given the introduction of the Automated Vehicles (AV) Act 2024. We will be considering data requirements as part of the authorisation for all forms of self-driving vehicles as part of the implementation of the act.

Under the Automated and Electric Vehicles Act 2018 (AEVA), the Secretary of State is mandated to list vehicles capable of self-driving, which are then classified as automated vehicles for insurance purposes. In 2021, the Department for Transport announced that vehicles compliant with the ALKS regulation are expected to meet the criteria for inclusion on this list. However, it was noted that the assessment of vehicles to add them to the list will be based on the information available at the time.

The AV Act 2024 replaces the listing process in AEVA 2018 with the authorisation process, once the authorisation process is commenced. The use of vehicles as self-driving will then be subject to authorisation and a suitable ASDE will need to be appointed as part of the process. At that point the listing requirement in AEVA 2018 ceases to exist and its references to listed vehicles is replaced with references to authorised vehicles under the AV Act 2024 – meaning that the insurance requirements in AEVA 2018 will then apply to authorised vehicles.

The Highway Code now includes a section outlining the responsibilities associated with operating vehicles listed under AEVA. In addition, the department collaborated with stakeholders to develop a resource pack detailing the roles and responsibilities for using listed vehicles equipped with ALKS technology.

Potential acceptance of EU approvals for eCall components

Currently, the GB scheme requires vehicles, systems and components to be approved to the relevant GB regulation, or where applicable, the relevant UNECE regulation.  We would welcome views on whether to accept EU approvals for subjects where the potential risks are considered to be low, for example, recognising EU component approvals for eCall.

This may strike the right balance between offering additional flexibility to the businesses that supply the components to vehicle manufacturers, while ensuring the VCA continues to have oversight of the eCall approval for the vehicle itself. If this approach is adopted, vehicle manufacturers would continue to require a GB eCall approval under the GB type approval scheme, but they would be able to use components with EU approval rather than requiring them to be covered by a GB component approval.

Areas where we are gathering views and evidence

The following measures are in areas where we would like to gather views and may take forward through a future statutory instrument.  

Lighting

The UN have consolidated multiple lighting regulations into 3 regulations for road illumination, signalling and reflective devices, UN regulations 148, 149 and 150.

We propose listing these UN regulations in GB approval, in addition to the existing lighting regulations, to clarify that manufacturers have the flexibility to choose which UN regulations to use when seeking GB whole vehicle approval.

Vehicle security

We propose to clarify the GB type approval regulations to mirror the change to UN security regulations. The existing security regulation (UN Regulation 116) has been split into 3 new regulations, covering unauthorised use devices, vehicle immobilisers and vehicle alarm systems, with no change to substance.

We therefore propose to list UN Regulations 161, 162, 163 in GB type approval, to ensure that the scheme recognises these approvals as alternatives to the existing UN requirements listed in the GB scheme.

Information document

We have received requests from manufacturers to amend the information document for single step and step-by-step approval respectively. (The templates for this are in Annexes I and II of assimilated Commission Implementing Regulation (EU) 2020/683.)

We understand that errors in the EU and GB versions of these annexes to Regulation (EU) 2020/683 has led to current numbering of the GB version being out of line with major manufacturers’ databases, for the items formerly numbered as follows:

• 2.11.4 technically permissible maximum mass of the combination
• 2.11.5 vehicle is/is not (1) suitable for towing loads

This has led to confusion for some manufacturers.

We propose to:

• revert to the original numbering of the 2 above-mentioned items
• renumber the rarely-used entry currently at 2.11.4 (maximum towable mass: rigid drawbar trailer) as item 2.11.7, together with two entries subsidiary to this one which will be re-numbered 2.11.7.1 and 2.11.7.2

This change will have the benefit of enabling existing databases which car manufacturers use for approval information to remain unchanged. However, we are keen to hear if these changes will inconvenience other manufacturers, for example truck manufacturers.

Conversions and electric safety requirements

There are a number of converters who take a goods vehicle chassis (category N1 or N2) and convert it into a special purpose vehicle designed to carry passengers (category M1 SPV) such as a wheelchair accessible vehicle or motor caravan.

We have been advised that these converters are naturally starting to consider converting electric vehicles.  The converted vehicle is then required to comply with the rules on electric safety, set out in UNECE Regulation 100, which apply to the final vehicle category, M1 in the case of wheelchair accessible vehicles. The rules differ slightly for some categories of vehicle and some converters are unable to modify the base vehicle or its powertrain (the main components that generate power in a motor vehicle) because they do not have expertise in electric powertrains.

It is already accepted in the regulations for multistage build vehicles to accept a converted vehicle meeting the standards applying those of the base vehicle category, for some subjects, for example, for steering equipment, indicated by the letter “G” in the table of requirements.

We would therefore welcome views on amending regulations to permit wheelchair accessible vehicle conversions on an N category base vehicles with an electric powertrain, provided the end product complies with N category rules for electrical safety in UNECE Regulation 100.

Weight of electric vehicle batteries in light goods vehicles

Electric vehicles (EVs) tend to weigh more than combustion engine vehicles. This is largely due to the weight of the battery within EVs.

This additional weight is considered when assessing whether a zero-emission vehicle is in or out of the scope of CO2 monitoring requirements, as set out in the Vehicle Emissions Trading Schemes Order 2023 in the UK. A vehicle of category N2 with a technically permissible maximum laden mass of 4,250kg or lower that is zero emission may be considered as a light goods vehicle for the purposes of emissions regulation, provided the excess mass above 3,500kg is attributable to the energy storage system.

The EU has made a new regulation - Regulation (EU) 2024/883 - requiring manufacturers of battery electric vehicles of category N (goods vehicle not exceeding 3500kg laden weight) to include the weight of batteries on the statutory (VIN) plate. The EU use the Gross Vehicle Weight minus the weight of the vehicle battery to determine whether a vehicle is in scope of monitoring. We therefore would welcome views on aligning with the approach taken in the EU in new regulation 2024/883.

Maximum weights when towing

When the Department for Transport amended assimilated EU legislation to create the GB type approval scheme, we omitted paragraph 2.7.2.2 of Commission Regulation (EU) No 1230/2012.

Vehicle manufacturers use this part of the Regulation to determine the Technically Permitted Maximum Laden Mass (TPMLM) of a vehicle.

We welcome views on amending the relevant regulation to reinstate para 2.7.2.2

Motorcycle helmet and eye protection

The following GB regulations require all helmets and visors worn when riding a motorcycle or moped on roads to meet certain safety standards:

• The Motor Cycles (Protective Helmets) Regulations 1998, as amended
• The Motor Cycles (Eye Protectors) Regulations 1999, as amended

The international UNECE standard for the approval of protective helmets and their visors for drivers and passengers of motorcycles and mopeds is UN Regulation 22. This has recently been updated, UN Regulation 22.06, to capture significant technological, design and engineering advancements in motorcycle helmet production. The GB regulations currently reference the preceding amendment of the UN Regulation 22 (R22.05).

The risk of not immediately updating the regulations is low. GB regulations prescribe that the types of recommended helmet must conform to either:

• UN Regulation 22.05
• British Standard 6658:1985 (BS)
• any other standard accepted by a European Economic Area (EEA) state which offers in-use equivalent levels of safety, suitability and fitness for purpose

We assess that helmets and visors approved to R22.06 offer improved levels of protection from injury relative to UN Regulation 22.05 and the British Standard and, therefore, comply with current GB regulations insofar as an EEA State has recognised the UN Regulation 22.06.

We propose to update the GB domestic regulations to directly reference wearing helmets and visors approved to UN Regulation 22.06 when driving or riding on a motorcycle or mopeds on roads and to remove ambiguity and ensure that the GB regulations accept UN regulations that the UK has signed.

How to respond

The simplest way to respond to this consultation is via the online response form.

You can find a link to the form and other ways to respond in the Ways to respond section of the GOV.UK homepage for this consultation.

The consultation began on 4 November 2024 and will run until 2 December 2024. Please ensure that your response reaches us before the closing date.

When responding, please state whether you are responding as an individual or representing the views of an organisation. If responding on behalf of a larger organisation, please make it clear who the organisation represents and, where applicable, how the views of members were assembled.

Full list of questions

The questions are listed here to give you an overview of what we are asking. See the Ways to respond section of the GOV.UK homepage for this consultation to answer the questions.

Personal details

Name:

Email address:

Are you responding as an individual or organisation?

Organisation questions (for organisations only)

Does your organisation represent other businesses?

If yes, how many businesses?

Questions about priority proposals

E-call

Do you agree or disagree with updating the eCall regulations?

If disagreeing, why?

If agreeing do you agree or disagree with providing end of series derogations for unsold vehicles that would otherwise become non-compliant with the revised eCall system requirements?

If disagreeing, why?

Windscreen wash and demist systems

Do you agree or disagree with updating the windscreen wash and demist systems regulations?

If disagreeing, why?

Vehicle Energy Consumption Calculation Tool (VECTO)

Do you agree or disagree with implementing the Vehicle Energy Consumption Calculation Tool?

If disagreeing, why?

ISOFIX

Do you agree or disagree with our clarifying the GB regulations for ISOFIX?

If disagreeing, why?

Automated Lane Keeping Systems (ALKS)

Do you agree or disagree with adding UN Regulation 157 into the GB type approval scheme to enable ALKS technology?

If disagreeing, why?

Potential future areas

We are gathering views on measures that we are currently considering and may take forward through future work.

The questions are listed here to give you an overview of what we are asking. See the Ways to respond section of the GOV.UK homepage for this consultation to answer the questions.

What comments, if any, do you have on:

• reflecting in the GB scheme the consolidation of multiple UN lighting regulations into 3 regulations for road illumination, signalling and reflective devices (UN Regulations No. 148, 149 and 150)
• reflecting in the GB scheme the new UN regulations on vehicle security (UN Regulations No. 161, 162, 163)
• our suggestions for updates to the information document
• our proposed approach on the technical requirements applicable to electrical safety for wheelchair accessibility conversions
• aligning with the EU’s approach in Regulation (EU) 2024/883 to require manufacturers of light goods vehicles to specify the mass FOR batteries for electric vehicles on the statutory plate
• how we should approach maximum weights when towing
• updating GB domestic regulations on motorcycle head and eye protection to requiring compliance with the latest UN regulation (UN Regulation 22.06)

Final comment

Any other comments?

What will happen next

We aim to publish a summary of responses, including the next steps, within three months of the consultation closing and lay a statutory instrument to bring forward our proposals, subject to stakeholder views and ministerial approval. Paper copies will be available on request.

If you have questions about this consultation, please contact:

International Vehicle Standards
3rd Floor, Zone 4
Great Minster House
33 Horseferry Rd
London
SW1P 4DR

Alternatively, please email ivs.consult@dft.gov.uk.

List of representative bodies consulted

SMMT (Society of Motor Manufacturers and Traders)

NCC (National Caravan Council)

The Camping and Caravan Club

The Caravan and Motorhome Club

NTTA (National Trailer & Towing Association)

WAVCA (Wheelchair Accessible Vehicle Convertors Association)

VBRA (Vehicle Builders and Repairers Association)

BIMTA (British Independent Motor Traders Association)

AIAA (American Import Agents Association)

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, in itself, be regarded as binding on the department.

Data protection 

The Department for Transport (DfT) is carrying out this consultation on proposed updates to the GB type approval regime.

This consultation and the processing of personal data that it entails is necessary for the exercise of our functions as a government department. If your answers contain any information, including the email address itself, that allows you to be identified, DfT will, under data protection law, be the controller for this information.

As part of this consultation, we’re asking for your name, email address and organisation. This is in case we need to ask you follow-up questions about any of your responses. You do not have to give us this personal information but if you do, we will only use it for the purpose of asking follow-up questions.  We will not use your name or other personal details that could identify you when we report the results of the consultation.

DfT’s privacy policy has more information about your rights in relation to your personal data, how to complain and how to contact the Data Protection Officer. 

In addition to this data, for organisations we are asking if they represent other businesses and if so, the number of businesses they represent.

Your information will be kept securely and destroyed within 12 months after the consultation has been completed.

Consultation principles

This consultation is being conducted in line with the government’s consultation principles.

If you have any general comments about the consultation process, contact:

Consultation Co-ordinator
Department for Transport
Zone 1/29 Great Minster House
London
SW1P 4DR

Email consultation@dft.gov.uk