Consultation outcome

Amendments to the UK trailer registration scheme: government response

Updated 12 October 2023

Executive summary

A trailer registration scheme was introduced in the United Kingdom as part of the requirements for the ratification of the 1968 Vienna Convention on Road Traffic (the Convention), which took place on 28 March 2018.

The purpose of the registration scheme is to enable the users of trailers that are kept in the UK, and which were unregistered, to avoid potential enforcement action in relation to the registration of the trailer while it was being used abroad when travelling to or through a country which is party to the Convention.

Since the introduction of the scheme, it has become clear that some minor amendments are required to ensure its continued effective operation. As a result, the Department for Transport (DfT) and the Driver and Vehicle Licensing Agency (DVLA) held a consultation on changes to the UK trailer registration scheme between 4 June 2021 and 2 July 2021.

To promote the consultation, we wrote to key stakeholders who we believed may have been particularly interested in the consultation to highlight its publication and to encourage them to respond if they had views on the proposals. The stakeholders contacted were:

• Road Haulage Association (RHA)
• Logistics UK (LUK)
• British Vehicle Rental and Leasing Association (BVRLA)
• National Trailer and Towing Association (NTTA)
• Camping and Caravanning Club (CCC)
• Caravan and Motorhome Club (CMC)
• British Horse Association (BHA)

The consultation covered 6 amendments. The first 4 were technical amendments, the fifth was made at the request of the Home Office, to facilitate the identification of trailers for the purpose of crime detection. The sixth amendment was proposed to clarify that mechanically propelled vehicles may not also be registered as trailers.

Summary of responses

There were 6 responses to the consultation, which are summarised on an amendment-by-amendment basis in the next section. Three responses came from stakeholder organisations that were specifically contacted, namely the RHA, LUK and CCC.

The consultation also received 2 responses from the Society of Motor Manufacturers and Traders (SMMT) and the Royal Automobile Club (RAC). The RAC only provided a response to the sixth amendment.

The remaining response came from an individual.

Only one respondent stated that they owned or operated trailers, which were described as either box trailers or caravans. However, these trailers were also stated as not being registered on the scheme.

A couple of key reasons that the trailers may be unregistered is that they:

• weigh less than 3.5 tonnes and are solely used outside of the UK for non-commercial purposes
• never leave the UK or only travel to countries that are not party to the Convention, such as Ireland

Responses to the proposed amendments

Amendment 1: alter the prescribed licence plate font to specify the Charles Wright font required by The Road Vehicles (Display of Registration Marks) Regulations 2001 (the display regulations)

Five responses were received, 4 of which supported the proposal as per the Road Vehicles (Display of Registration Marks) Regulations 2001 (the display regulations). Comments from the latter related to ensuring that customers were not disadvantaged by the change and were able to continue to use plates already attached to their trailers.

There was one objection to the proposal, which suggested that the change should be used as an opportunity to add additional information to the plate, specifically in relation to the environmental credentials of the trailer, so that the user of the trailer could demonstrate that they were not taking polluting equipment into the European Union.

Amendment 2: removing the requirement for inspection of a trailer to only be carried out at a designated testing station

Five responses were received. They all supported this proposal principally as it offers flexibility for trailer owners and users.

Associated comments related to:

• ensuring there are enough locations
• seeking a criteria that people carrying out inspections of small trailers should adhere to when conducting an inspection

Amendment 3: abolishment of the further trailer inspection fee following an appeal

The removal of the fee for an inspection following an appeal was supported by all 5 respondents. One agreed with the caveat that those conducting an inspection do not incur a financial or administrative burden as a result.

Amendment 4: reducing the maximum period before a keeper can apply for a renewed trailer documentation from 1 year to 6 months

Five responses were received to this question, which were all supportive of this proposal. The shorter renewal window was seen as adequate given the 10-year registration validity, provided that customers with registered trailers were given suitable reminders when the registration was due to expire.

Amendment 5: the addition of trailer type details when registering a trailer

There were 5 responses to this question, 4 of which were supportive. There was a view that the list of trailers should be standardised to ensure consistency in the registration process and trailer descriptions. One respondent sought for all existing registrations to be updated to include this information within a 6-month period.

The one objection sought for the scheme to be made mandatory to cover all trailers and to particularly identify where trailers had power derived from diesel generators. For example, a refrigerated trailer may therefore fall foul of clean air zones.

Amendment 6: amending the registration regulations so that mechanically propelled vehicles and towed vehicles cannot also be registered as trailers

Six responses were received to this consultation question, all of which agreed with the proposal to amend the underlying regulations to clarify that mechanically propelled motor vehicles – such as a small car that may be towed behind a motorhome using an A-frame device – cannot also be registered as a trailer.

One stakeholder noted that they had expressed concerns to DVLA about this previously and were pleased to see this amendment was now being proposed.

Summary of other comments

Two respondents made further comments relating to the current scheme.

One sought for all new trailers in the UK to be registered on the scheme and for details of any equipment installed on the trailer to be specified, especially if the equipment produced emissions.

They also sought for the registration document for refrigerated trailers to show information regarding the certification for agreement on the international carriage of perishable foodstuffs and on the special equipment to be used for such carriage (ATP) and fluorinated gas (F gas) testing.

One respondent sought for data sharing provisions to be updated to permit the sharing of data collected under the scheme. They noted that this would bring the trailer market in line with the powered vehicle market where the DVLA has the legal power under regulation 27 of the Road Vehicles (Registration and Licensing) Regulations 2002 (as amended) to “make any particulars contained in the register available for use by any person who can show to the satisfaction of the Secretary of State that he has reasonable cause for wanting the particulars to be made available to him”.

Next steps

Following the conclusion of the consultation and consideration of the responses, DfT and DVLA introduced legislation – The Trailer Registration (Amendment) Regulations 2021 that implemented the proposed changes.