Consultation outcome

Updating GB type approval for road vehicles

Updated 6 March 2024

This was published under the 2022 to 2024 Sunak Conservative government

Applies to England, Scotland and Wales

Introduction

Motor vehicles are required to be type-approved against safety and environmental rules before they go on sale. This enables government agencies to ensure that manufacturers are producing vehicles that comply with the safety and environmental obligations set out in legislation.

We have recently introduced an independent type approval scheme, GB type approval.

Manufacturers currently using provisional GB type approval, which recognises vehicles approved to EU requirements, for road vehicles will need to apply to the Vehicle Certification Agency (VCA) for GB type approval.

For motor vehicles, this applies to new models introduced to the market on or after 1 February 2024, and to all models which are to be produced on or after 1 February 2026. For trailers towed behind motor vehicles, the applicable dates are one year later, in other words 1 February 2025 and 1 February 2027.

In the last few years there have been numerous developments in vehicle regulations internationally, and we are in the process of considering whether these should be incorporated in the GB scheme.

This consultation covers 2 proposals:

We propose to accept approvals to some international (UNECE) regulations which the UK has signed and thus undertaken to accept. The most important proposal here is whether to accept the latest internationally agreed emissions standards for cars and light goods vehicles, sometimes known as Euro 6e.

We have identified some subjects which are of lower priority in safety or environmental terms. We are considering whether to permit manufacturers to test to certain alternative specifications in these subjects, that provide the same or a comparable level of safety or environmental protection. This consultation proposes to accept one specification used in an international market, which industry has identified as beneficial. A future consultation will seek your detailed views on this concept.

UNECE regulations

There is a great deal of international harmonisation of road vehicle regulations, chiefly via the United Nations Economic Commission for Europe, or UNECE.

The UK is a contracting party to the UNECE’s 1958 Agreement, Revision 3.

This is an international agreement relating to reciprocal recognition of vehicle approvals.

Governments (‘contracting parties’) that sign up to an internationally agreed specification (‘UNECE regulation’) are permitted to issue approvals to vehicles or components that comply with that regulation. Contracting parties must accept vehicles and components type-approved by another contracting party against a UNECE regulation that they are a signatory to.

The benefits of international harmonisation include that it reduces the complexity faced by manufacturers in attempting to understand and test vehicles to numerous national standards, and gives rise to economies of scale in manufacture, thus lowering costs.

We are proposing to update domestic legislation to ensure that the scheme accepts UNECE regulations that the UK has signed and thus indicated that it will accept, for subjects that currently form part of the GB type approval scheme. This includes UNECE regulations covering the latest Euro 6e emissions standards for cars and light goods vehicles, facilitating the sale of cleaner vehicles in Great Britain, and permitting manufacturers to sell the same specification of vehicle in Britain as they sell in Europe and Northern Ireland.

Emissions regulations

The new GB Whole Vehicle Type Approval scheme (GB WVTA) becomes mandatory for all new vehicle types from February 2024, and all models which are to be produced on or after 1 February 2026 of motor vehicles for carrying passengers or goods (known as categories M and N). Within this, vehicles have to be tested for pollutant emissions.

The current Euro 6 emissions standard which applies to light duty vehicles (cars and vans) contains sub-steps indicated by letters, with the GB scheme currently requiring Euro 6d.

Internationally, the UNECE have very recently adopted the Euro 6e standard. The EU have also adopted Euro 6e into their type approval scheme which applies to vehicles sold in Northern Ireland under the obligations set out in the Windsor Framework, and thus Euro 6e will become compulsory for vehicles sold in Northern Ireland in due course.

Euro 6e includes changes to the laboratory and on-road test procedures. Overall, it is a more stringent environmental requirement for vehicle manufacturers to meet than Euro 6d, but certification to Euro 6e does not automatically guarantee compliance with Euro 6d.

Manufacturers who operate in both EU and GB markets have indicated that they intend to sell models of vehicle complying with Euro 6e in both markets but would naturally prefer not to also test those models against the Euro 6d requirements, which would amount to double testing.

We are therefore proposing to amend our regulations to permit manufacturers to use the UNECE Regulations which contain the Euro 6e requirements (listed in Table 1) to certify compliance with GB requirements for Euro 6d. This will permit cleaner vehicles, improving air quality, without the manufacturers incurring the cost of double testing.

Manufacturers will be allowed to continue to produce Euro 6d vehicles for the market in Great Britain until further notice: they can continue to demonstrate compliance via Euro 6d testing. Future emissions requirements for vehicles to be sold in GB are being assessed and may be consulted upon in future.

There is a similar situation for heavy-duty vehicles: buses and heavy goods vehicles. The Euro 6 step E emissions standard is specified in UNECE Regulation 49 and is compulsory for new vehicles sold in Northern Ireland, while step D applies in GB, although we understand that the majority of heavy vehicles sold in GB already comply with step E.

Other requirements

We have reviewed the latest UNECE regulation on tyre Installation (Regulation 142) and it is identical to the GB requirements for tyres. We therefore intend to give effect to our international obligations by referring to it in the GB type approval scheme.

Regulation (EU) 2018/858 sets the type approval framework for the EU, and the retained version of this regulation is still applicable in Great Britain and with numerous amendments forms the basis of the GB type approval scheme. There are some UNECE Regulations which were previously accepted, but due to an error in Regulation (EU) 2018/858, are no longer specified. We will take this opportunity to correct our legislation, and update footnotes which were previously applicable when we were an EU member state. This is outlined in Table 1.

New electric vehicles are very quiet so are required by law to emit a special sound at low speeds, to assist groups such as the blind who might not otherwise be aware of their presence. UNECE Regulation 138 on Quiet Road Transport Vehicles (QRTV) regulates this special sound and has been signed by the UK so needs to be accepted in the GB scheme.

We propose that the GB scheme should accept solely the 138.01 series of amendments, and not the earlier 138.00 series of amendments. This is in line with the relevant retained law, Regulation (EU) 2019/839, where a pause function on the acoustic vehicle alerting system (AVAS) is now prohibited on the newest vehicles.

As we are making corrections, we also propose to make a correction which will ensure that tyre manufacturers can be appointed as a technical service for the purposes of assessing tyre rolling resistance in the CO2 calculation scheme for heavy lorries, known as VECTO. This was previously permitted but was omitted due to an error in Regulation (EU) 2018/858.

Lower priority subjects and alternative specifications

There are around 70 subjects in GB approval where vehicles are required to be tested, depending on category. For a large proportion of these, UNECE regulations exist, thus minimising the test burden on manufacturers, as they are likely to be obtaining the UNECE approvals for a variety of other markets.

For the remaining subjects not covered by UNECE regulations, there are unique GB specifications in around 20 areas. After careful consideration, we have decided that there may be benefits from giving manufacturers the choice of testing to alternative requirements to those currently laid out in the approval scheme.

This would initially be limited to the subjects where we are confident that the impact on safety or the environment of accepting alternative standards is limited or non-existent, but where the benefit to manufacturers of accepting alternative, equivalent, specifications from other markets may be substantial.

Industry have flagged that the technical specification for the rear registration plate space in EU approval (Annex III to Regulation (EU) 2021/535) has diverged from that in GB approval, and that it would be a priority for them if we could accept the equivalent EU specification. The differences do not affect safety or the visibility of the plate so we consider it appropriate to accept this.

As a first step, therefore, we propose to accept vehicles meeting the EU specification for rear registration plate space. This would be demonstrated by a test report from a designated technical service. The VCA as the GB approval authority will retain the ultimate say over whether the test report is an acceptable demonstration of compliance.

We will be requesting comment on additional potential changes of this nature in due course.

Table 1: UNECE regulations accepted

This table shows how the table in Part II of Annex II of Regulation (EU) 2018/858 will look, after the proposed amendment.

	Subject	UN Regulations	Series of amendments	Source
1[1]	Permissible sound level	51	02	Correcting error
	Replacement silencing systems	59	01	Correcting error
1A	Permissible sound level (not covering AVAS and replacement silencers)	51	03	No changes
	Acoustic Vehicle Alerting System (AVAS)	138	01	New proposal
	Replacement silencing systems	59	02	No changes
2A	LD exhaust emissions (diesel smoke)	24	03	New proposal
	LD exhaust emissions (does not cover diesel smoke, engine power, WLTP, RDE) [2]	83	08	New proposal
	LD exhaust emissions (engine power)	85	00	New proposal
	LD exhaust emissions (WLTP)	154	02 Level 1A	New proposal
	LD exhaust emissions (RDE)	[168]	00	New proposal
41A	HD exhaust emissions (diesel smoke)	24	03	New proposal
	HD exhaust emissions (does not cover determination of CO2 via VECTO)	49	07	New proposal
	HD exhaust emissions (engine power)	85	00	New proposal
46A	Installation of tyres (not covering trailers nor a vehicle fitted with C3 tyres)	142	00	New proposal
46A	Installation of tyres	142	01	New proposal
58	Pedestrian protection (not covering brake assist and frontal protection systems)	127	00	No changes
	Brake assist system	13-H	00 (Supp 9 or above)	No changes
	Brake assist system	139	00	No changes
59	Recyclability [3]	133	00	Correcting error
62	Hydrogen storage systems [4]	134	00	Correcting error
65	Advanced emergency braking systems	131	01	No changes
66	Lane departure warning system	130	00	No changes

[1] The numbering of the entries in this table refers to the numbering used in the table of Part I of Annex II to Regulation (EU) 2018/858 as it applies in Great Britain.

[2] For pure electric vehicles, evidence of compliance with paragraph 3 (a) (ii) of the Regulation (anti-tampering measures applied in relation to the odometer) is considered as equivalent to holding an approval to this regulation.

[3] In addition, paragraph 4(3) of Schedule A1 of the Road Vehicles (Approval) Regulations 2020 (SI 2022/1273) applies.

[4] The component type-approval provided for in the UN regulation of hydrogen storage systems, automatic shut-off valves, check or non-return valves and thermally activated pressure relieve devices is mandatory. Also, the UN regulation does not cover the obligatory material qualification of all components that are covered by Article 2(2) of Regulation (EC) No 79/2009 of the European Parliament and of the Council.

How to respond

The questions we are asking are listed in the following section of this document. You can respond to them via email or post.

See the Ways to respond section of the GOV.UK home page for this consultation for:

• a response form that you can email to us
• a postal address if you prefer to post your response

The consultation began on 12 October 2023 and will run until 10 November 2023. Please ensure that your response reaches us before the closing date.

When responding, please state whether you are responding as an individual or representing the views of an organisation. If responding on behalf of a larger organisation, please make it clear who the organisation represents and, where applicable, how the views of members were assembled.

Full list of questions

UNECE Regulations

1. Do you have any comments on our proposals on accepting UNECE Regulations on Euro 6e emissions for cars and light goods vehicles?

2. Do you have any comments on our proposals on accepting the UNECE Regulations for tyres, added sound for quiet vehicles, modifying some of the footnotes to the table, or on the other proposals correcting errors (listed in Table 1)?

Lower priority subjects and alternative standards

3. Do you agree that the EU standard on rear registration plate space should be accepted as an alternative to the GB rules on this topic?

Other comments

4. Please provide any other comments you may have on the GB type approval scheme, for consideration in relation to potential future amendments.

What will happen next

We aim to publish a summary of responses, including the next steps, within 3 months of the consultation closing. Paper copies will be available on request.

If you have questions about this consultation, please contact:

International Vehicle Standards
1st Floor, Zone 4
Great Minster House
33 Horseferry Rd
London
SW1P 4DR

Alternatively, please email ivs.consult@dft.gov.uk.

List of representative bodies consulted

SMMT (Society of Motor Manufacturers and Traders)

NCC (National Caravan Council)

NTTA (National Trailer & Towing Association)

WAVCA (Wheelchair Accessible Vehicle Convertors Association)

VBRA (Vehicle Builders and Repairers Association)

BIMTA (British Independent Motor Traders Association)

AIAA (American Import Agents Association)

British Tyre Manufacturers Association

Imported Tyre Manufacturers’ Association

The National Tyre Distributors Association

Freedom of information

Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the Freedom of Information Act 2000 (FOIA) or the Environmental Information Regulations 2004.

If you want information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a statutory code of practice with which public authorities must comply and which deals, amongst other things, with obligations of confidence.

In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information, we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the department.

Data protection 

The Department for Transport (DfT) is carrying out this consultation to decide whether to introduce the option of complying with new international regulations into the GB type approval scheme for road vehicles. 

This consultation and the processing of personal data that it entails is necessary for the exercise of our functions as a government department. If your answers contain any information, including the email address itself, that allows you to be identified, DfT will, under data protection law, be the controller for this information.

As part of this consultation, we’re asking for your name, email address and organisation. This is in case we need to ask you follow-up questions about any of your responses. You do not have to give us this personal information but if you do we will only use it only for the purpose of asking follow-up questions.  We will not use your name or other personal details that could identify you when we report the results of the consultation.

DfT’s privacy policy has more information about your rights in relation to your personal data, how to complain and how to contact the Data Protection Officer. 

Your information will be kept securely and destroyed within 12 months after the consultation has been completed.

Consultation principles

This consultation is being conducted in line with the government’s consultation principles.

If you have any general comments about the consultation process, contact:

Consultation Co-ordinator
Department for Transport
Zone 1/29 Great Minster House
London SW1P 4DR

Email consultation@dft.gov.uk.