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This publication is available at https://www.gov.uk/government/publications/vehicle-type-approval-if-theres-no-brexit-deal/vehicle-type-approval-if-theres-no-brexit-deal
A scenario in which the UK leaves the EU without agreement (a ‘no deal’ scenario) remains unlikely given the mutual interests of the UK and the EU in securing a negotiated outcome.
Negotiations are progressing well and both we and the EU continue to work hard to seek a positive deal. However, it’s our duty as a responsible government to prepare for all eventualities, including ‘no deal’, until we can be certain of the outcome of those negotiations.
For two years, the government has been implementing a significant programme of work to ensure the UK will be ready from day 1 in all scenarios, including a potential ‘no deal’ outcome in March 2019.
It has always been the case that as we get nearer to March 2019, preparations for a no deal scenario would have to be accelerated. Such an acceleration does not reflect an increased likelihood of a ‘no deal’ outcome. Rather it is about ensuring our plans are in place in the unlikely scenario that they need to be relied upon.
This series of technical notices sets out information to allow businesses and citizens to understand what they would need to do in a ‘no deal’ scenario, so they can make informed plans and preparations.
This guidance is part of that series.
Also included is an overarching framing notice explaining the government’s overarching approach to preparing the UK for this outcome in order to minimise disruption and ensure a smooth and orderly exit in all scenarios.
We are working with the devolved administrations on technical notices and we will continue to do so as plans develop.
This notice explains the contingency plans the Department for Transport (DfT) and the Vehicle Certification Agency (VCA) would implement in order to allow vehicle and component manufacturers to place new products on the market if the UK leaves the EU in March 2019 without an agreement.
Motorists and fleet operators would not be affected by these plans and they would not apply to vehicles currently on the road.
Before 29 March 2019
Vehicle and component manufacturers must show they comply with safety and environmental standards before they can place a product on the market for sale. This process is known as type-approval.
Currently, these standards are set out in the framework regulations on European Community Whole Vehicle Type-Approval (ECWVTA) and those on the approval of non-road mobile machinery.
For a vehicle to be sold and registered in the EU, the manufacturer must hold an European Community type-approval (EC type-approval) issued by the type-approval authority in an EU country. Some components may also need EC type-approval.
Type-approval authorities may appoint separate bodies, known as ‘technical services’, to test that vehicles adhere to the safety and environmental standards. Type-approval authorities also carry out quality reviews to ensure that manufacturers continue to build compliant vehicles. The VCA is the UK’s type-approval authority. It also acts as a technical service.
The UK is also a contracting party to the UN-ECE (United Nations Economic Commission for Europe), and recognises approvals to its standards for systems and components. These approvals make up the majority of the system and component approvals required for ECWVTA.
After March 2019 if there’s no deal
In a no deal scenario, type-approvals issued in the UK would no longer be valid for sales or registrations on the EU market. EC type-approvals issued outside of the UK, would no longer be automatically accepted on the UK market.
This means that affected manufacturers would need to ensure that they have the correct type-approval for each market.
The UK will continue to recognise UN-ECE approvals for systems and components.
VCA would continue to act as a technical service for the purpose of testing for UK type-approvals. However, it may no longer be recognised as a technical service by EU type-approval authorities.
Type-approval only applies to manufacturers. For motorists and fleet operators, a no deal scenario would not prevent them from driving cars they own or may buy either in the UK or abroad. There are no implications for owners of vehicles registered either in the UK or abroad before the UK leaves the EU.
What you would need to do
Existing vehicle and component approvals
Vehicle and, where relevant, component manufacturers, would need to obtain a UK type-approval before placing their products on the UK market. EC type-approvals would no longer be valid for this purpose.
Existing EC type-approvals would need to be converted into a UK type-approval to allow manufacturers to continue to place products on the market in the UK.
Further information on this process will be made available in due course and in sufficient time to ensure approvals are issued by exit day. Upon exit, UK and EU technical standards would be fully aligned.
The UK plans to issue provisional UK type-approvals to manufacturers that already have EC type-approvals. This would be an administrative conversion of EC type-approvals into UK type-approvals. This streamlined approach would ensure that products can continue to be sold and registered in the UK.
This provisional approval would be time-limited (for example 2 years). During this period, manufacturers would be able to approach the VCA to request a full conversion of their EC type-approval to a UK type-approval. This approach avoids costly re-testing and re-design for manufacturers. The VCA reserves the right to require additional administrative and conformity of production checks for the granting of the full UK type approval, where evidence supports the need for this approach.
We will provide more information about how manufacturers can apply for a provisional UK type-approval later in 2018.
Manufacturers currently holding a VCA-issued EC type-approval, who intend to continue placing their products on the EU market, must obtain a new EC type-approval from a type-approval authority in an EU country. This process is set out in the European Commission’s legislative proposal published in June this year. We expect to see agreement on this proposal in the near future. Further specific information on how the process works will be set out by the European Commission in due course.
New vehicle and component approvals
Manufacturers who are in the process of obtaining a new EU approval at the point of exit or intend to place a new vehicle models or components onto the UK market after exit day would need to obtain a UK type-approval. They must comply with the requirements of the UK type-approval scheme, which will be fully aligned with the requirements for ECWVTA immediately after exit.
The VCA would grant a UK type-approval where a manufacturer can demonstrate it holds a valid EC type-approval issued post exit. Where necessary, the VCA would carry out conformity of production checks and review the documentary evidence, including test reports and approval certificates.
As the UK will be aligned with EU regulations at the time of EU exit, it is not envisaged that duplicate testing would be required as long as the VCA is satisfied with the documentary evidence provided.
Manufacturers wishing to place new products on the EU market after exit would need to follow the existing procedure for obtaining a new EC type-approval. Full testing and certification must be done by an EU type-approval authority and a technical service designated by that authority.
Vehicle categories and engines subject to EC type-approval
- passenger cars (M1)
- mini-buses (M2)
- buses and coaches (M3)
- light goods vehicles, car derived vans (N1)
- goods vehicles up to 12 tonnes (N2)
- goods vehicles over 12 tonnes (N3)
Trailers for road vehicles:
- light trailers (O1)
- trailers up to 3.5 tonnes (O2)
- trailers up to 10 tonnes (O3)
- trailers over 10 tonnes (O4)
- mopeds and powered cycles (L1)
- 3-wheel Mopeds (L2)
- motorcycles (L3)
- motorcycles with sidecar (L4)
- powered tricycles (L5)
- light quadricycles (L6)
- heavy quadricycles (L7)
Agricultural and forestry vehicles:
- wheeled Tractors (T)
- tracked Tractors (C)
Engines for non-road mobile machinery including:
- small gardening and handheld equipment (lawn mowers, chainsaws, etc)
- construction machinery (excavators, loaders, bulldozers, etc)
- agricultural & farming machinery (harvesters, cultivators, etc)
- railcars, locomotives and inland waterway vessels
Find out more about:
We will publish more information in the coming months. We aim to give businesses and individuals as much certainty as possible as soon as we can, and to ensure that any new requirements are not unduly burdensome.
This notice is meant for guidance only. You should consider whether you need separate professional advice before making specific preparations.
It is part of the government’s ongoing programme of planning for all possible outcomes. We expect to negotiate a successful deal with the EU.
Norway, Iceland and Liechtenstein are party to the Agreement on the European Economic Area and participate in other EU arrangements. As such, in many areas, these countries adopt EU rules. Where this is the case, these technical notices may also apply to them, and EEA businesses and citizens should consider whether they need to take any steps to prepare for a ‘no deal’ scenario.