101 UK Brexit Notes

Connemara Programme October 16 2018 pg. 91 Business: Approvals: Vehicle Types and Components Purpose 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 a 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.