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The Independent Automotive Aftermarket Federation

EU Exit No-Deal preparations – Vehicle Type Approval


Date: 23-Aug-2019

The Dept. for Transport has been in touch with the IAAF to given an update on the EU Exit Team's work on International Vehicle Standards.  The EU Exit work at the Department has continued throughout the period since the extension of Article 50 to 31st October, maintaining its no deal preparations. 

The UK will be leaving the EU on 31st October whatever the circumstances, and whilst the Government will work in an energetic and determined way to ensure the UK leaves with a deal, if that proves impossible the UK will have to leave with no deal. The Department is making all the necessary preparations to ensure they are prepared for all scenarios.

The Dept. for Transport has issued a reminder that, in the event of a no-deal exit on the 31st October, provisional UK type approvals will be required before new motor vehicles can be sold and registered in the UK.  If an application to the Vehicle Certification Agency (VCA) for approval has been completed, the VCA will issue a provisional UK approval upon Exit. If there are any changes or extensions to approvals which have already submitted, please inform the VCA. The application process for provisional approvals has remained open since March, and if you have not yet applied to the VCA, please get in touch with them as soon as possible via UKTA@vca.gov.uk. 

If you have an ‘e11’ EU approval issued by the VCA you will not be able to sell new products in the EU after a no-deal exit under this approval. If you wish to continue selling into the EU you should consider transferring to an EU27 approval authority. The VCA can assist you, so should you wish to use their service please start this process as soon as possible, and by no later than 15th September. There is a dependency on other Member States to issue the type approvals, and early application will give the greatest possibility that you can be covered before Exit.

If you do not want to proceed through the VCA, it would still be helpful to let them know if you are transferring. Any ‘e11’ approvals not transferred will remain valid in the UK but will no longer be accepted in the EU after exit. 

The Dept. for Transport also wants to draw your attention to a Statutory Instrument laid by the Department in July which complements their existing no deal secondary legislation. This instrument serves two purposes. The previous legislation, drafted on the basis of EU Exit in March 2019, doubled the annual limits for UK National Small Series Type Approvals until 31st December 2019. Due to the change in date of exit, this has now been extended and the period will expire on the 31st December 2020. The Department has also reviewed the limits themselves following stakeholder feedback. For passenger cars (M1) and light vans (N1) the annual limits will be 1,000 vehicles. For other vehicle categories the limits are double those currently specified in Annex XII of 2007/46/EC. This measure is intended to assist small manufacturers who sell only to the UK market prior to the implementation of the full UK type approval schemes.

The second purpose of this SI is to revoke the application of EU Regulation 2019/26 in the UK after exit. The purpose of this EU regulation is to allow the transfer of ‘e11’ approvals to the approval authority of another EU member state. Once the UK leaves the EU, this regulation ceases to be relevant and should not therefore be retained in UK legislation. The legislation can be found here.

The Department has also continued work on the legislation underpinning the new full UK type approval scheme which will replace the provisional scheme in due course. They expect to consult on this in December 2019.

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