Type approval advice from 1st January 2021
With only one month until the end of the Brexit transition period and still no confirmation on a trade deal I thought I would offer a brief reminder of the situation with regard to vehicle type approvals from 1st January 2021. Here are some of the headline items:
From 1st January 2021:
Existing EU vehicle type approvals issued by other EU-27 member states will no longer be automatically accepted in GB.
GB will issue provisional (p11) approvals to manufacturers holding valid EU vehicle approvals – valid for up to two years.
EU vehicle type approvals issued by UK (e11) will no longer be valid in the EU.
New vehicle types can obtain a provisional GB approval using a valid EU approval.
From 1st January 2021 to 1st January 2022:
Products not requiring registration (trailers, NRMM etc) can be placed on GB market with a valid EU approval while a GB approval scheme for these is developed.
Things to remember:
If you currently sell vehicles in the UK using a type approval from an EU-27 member state, ensure the VCA are aware so provisional GB approvals can be prepared for issue 1st January 2021.
If you currently sell vehicles in EU using an e11 approval you need to switch this to the approval authority of an EU-27 state
If you currently sell only in the UK using an e11 approval, no action is required.
GB provisional type approvals apply to whole vehicle approvals only – there is no need to convert system or component approvals.
For multi-stage EU type approvals, a provisional GB type approval is only needed for the final stage of production (complete or completed vehicles). Where the base vehicle has an EU type approval (whether incomplete or complete), or an intermediate stage, it does not need to be converted.
National Small Series and Individual Vehicle Approval Schemes are not impacted.
Other things to note:
GB Type Approval Scheme planned for 2022, after an initial consultation.
UK is a contracting party to the United Nations Economic Commission for Europe’s 1958 Agreement (UN-ECE) and will continue to recognise UNECE approvals for systems and components
EU Certificates of Conformity and statutory plates are still needed for vehicles with provisional GB approvals
The situation in Northern Ireland is a little more complex due to the Northern Ireland Protocol. EU approvals can still be used for sale and registration in Northern Ireland. UKNI approval is available for those who only sell in GB and NI
No one really knows what is going to happen next year; after the year we have had anything could happen! Lets just hope it all goes as smoothly as possible.
If you require any advice or support, please do not hesitate to contact me.
Castec Consulting Limited an independent Vehicle Type Approval, Certification and Compliance consultancy.
We provide specialist services, predominantly in the automotive sector, for companies in the UK and globally seeking assistance in a range of areas including; Type Approval and Compliance, Vehicle Technology and Safety Research, plus the interpretation of automotive legislation.
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