Research and analysis

Vehicle Market Surveillance Unit: results of the 2024 programme

Published 21 January 2025

Introduction

The Driver and Vehicle Standards Agency (DVSA) has a market surveillance unit, which inspects vehicles, trailers and equipment to make sure they meet safety and environmental standards.

This report sets out the findings of vehicle and component testing during 2024.

There’s a different report on the Vehicle Market Surveillance Unit’s 2024 emissions testing programme.

1. Aftermarket emissions components: testing

Aim of the programme

To determine the compliance of aftermarket emissions components supplied into the UK market. Specifically, catalytic converters (CATs) and diesel particulate filters (DPFs).

What we did

To test the components, we chose 3 vehicle models that have large aftermarket sales of catalytic converters and diesel particulate filters. A used model was purchased for each of these in order to test the components on.

Volkswagen Polo 1.2 (petrol)

We tested 5 catalytic converters against legislative standards for this vehicle.

They were:

• BM Catalysts BM91712H
• European Exhaust & Catalyst (EEC) VK6133T
• Walker 28058
• Bosal 090-805
• Vegaz SEK951 (relabelled Veneporte part)

Vauxhall Corsa 1.3 (diesel)

We tested 4 diesel particulate filters against legislative standards for this vehicle.

They were:

• Cats & Pipes GMF196
• Walker 73043
• Bosal 097-575
• EuroFlo EPGM7028TA (relabelled AS part)

Nissan Qashqai 1.5 (diesel)

We identified 3 diesel particulate filters for this vehicle.

They were:

• Cats & Pipes DNF123
• Walker 93078
• EuroFlo EPDN7006TA (relabelled AS part)

What we found

Of the 5 components tested on Volkswagen Polo 1.2, 2 components were found to not meet legislative standards. They were identified as European Exhaust & Catalyst VK6133T and Bosal 090-805.

Of the 4 components tested on Vauxhall Corsa 1.3, all 4 components were found to not meet legislative standards.

There were some technical challenges with the Nissan Qashqai that prevented the vehicle and the components being tested, so testing ceased, and the vehicle was referred to Nissan for further investigation.

Of the 9 components, 2 (European Exhaust & Catalyst and Cats & Pipes) are UK manufacturers and the remaining (Walker, Bosal, AS) are non-UK manufacturers.

Next steps

We have written to the UK manufacturers of the failed components, requesting an explanation of noted failures before considering further sanctions. We are currently awaiting the results from further testing by the manufacturers.

We have reported issues found with non-UK manufacturers to the relevant granting type approval authorities.

We’ll continue our market surveillance of aftermarket sales of catalytic converters and diesel particulate filters into the 2024 to 2025 programme to make sure these components meet legislative emissions requirements.

2. Non-road mobile machinery (NRMM) and agricultural and forestry vehicles

Aim of the programme

To check the supply of new non-road mobile machinery (NRMM) for sale in the UK, focusing on smaller imported products, to make sure that the engines:

• met the type-approval requirements.
• have the relevant approval markings as prescribed in the Non-Road Mobile Machinery (Type-Approval and Emission of Gaseous and Particulate Pollutants) Regulations 2018

To check the supply of new agricultural and forestry vehicles for sale in the UK to ensure the vehicles met the type-approval requirements as required in the Agricultural and Forestry Vehicles (Type-Approval) Regulations 2018.

What we did

We carried out open source research on more than 100 UK-based online suppliers of NRMM. We sent requests for type approval information to 10 of these suppliers with type approval information received for all relevant products. Across the year, we bought 29 NRMM products from online platforms.

We carried out open source research of suppliers of agricultural and forestry machines. Requests for type approval information were sent to 4 suppliers within the UK and EU with type approval information received for all relevant products.

We also attended 3 industry exhibitions across the UK with no non-compliant products identified.

What we found

We found that 22 of the NRMM products purchased did not have relevant type approval markings. We contacted the online platforms, and the products were removed from sale.

Next steps

Our work in 2025 will continue to be shaped by the ongoing concern regarding the small NRMM products available on the UK market through online platforms. We’ll do further research online and continue to make test purchases.

We’ll continue to research agricultural forestry machines and check type-approval certification for machines placed on the UK market through distributors and online selling platforms.

We’ll check to make sure that products for sale have the relevant type approval.

3. Motorcycle exhaust systems and silencers

Aim of the programme

To check aftermarket motorcycle exhaust systems and silencers on the market in the UK to make sure that they were:

• indelibly marked as required by regulations
• advertised and supplied correctly

The aim was to test a sample of aftermarket exhausts and silencers, both approved and non-approved, to assess compliance with noise approval standards.

What we did

We checked 32 manufacturers, distributors and retailers as potential suppliers of aftermarket motorcycle exhaust systems and silencers to establish whether they were compliant with the legislative requirements for noise.

Of these:

• 23 were selling via their own website
• 1 was selling via Amazon
• 1 was selling via eBay
• 5 were selling at industry-related events

We carried out 2 establishment visits in England.

Broad market surveillance was also carried out across online selling platforms to identify non-compliant aftermarket exhaust systems and silencers for sale into the UK market. We test purchased 26 different exhausts and silencers directly from suppliers and checked for the required approval or relevant markings.

What we found

We found that:

• 9 were approved
• 3 were marked as complying with the relevant British Standards
• 2 were marked as “not for road use” or “pre-1985 MC only”
• 12 were non-compliant and had no approval markings or other relevant markings as required by regulations

We test purchased 8 different types of aftermarket silencers from online selling platforms, none of which met the required regulations. Two were counterfeit products using well-known brand names. Over 700 listings and non-compliant products were removed from online selling platforms.

We attended 3 industry-related events where one manufacturer was displaying approved aftermarket exhaust systems. A further 4 were displaying multiple aftermarket silencers bearing no markings of any kind.

We have written to manufacturers and distributors of the non-compliant products and instructed them to bring their products and advertising into compliance. All but 3 have responded positively and the remaining 3 are being followed up further.

Tests

We tested 13 aftermarket exhaust systems and silencers across 3 different types of motorcycle:

• 2019 Honda CB125F
• 2018 Honda CBR500R
• 2019 Kawasaki Z1000SX

We chose these motorcycles due to their popularity in the UK and range of available aftermarket exhausts.

The bikes were independently laboratory tested with the original exhaust (OEM) fitted to establish baseline noise values and conformity with regulations.

We tested 4 aftermarket exhaust systems and silencers for the Honda CB125F. One was approved, one was declared as meeting British Standards and 2 were non-approved products.

We tested 6 aftermarket exhaust systems and silencers for the Honda CBR500R. Five were approved products and one was declared as meeting British Standards.

We tested 3 aftermarket exhaust systems and silencers for the Kawasaki Z1000SX. All 3 were approved products.

What we found

We found that of the 4 aftermarket silencers tested for the Honda CB125F motorcycle, all 4 exceeded the noise limits permitted under regulations.

Of the 6 aftermarket products tested for the Honda CBR500R motorcycle, 5 products exceeded the permitted noise limits and one was quieter than the noise emitted from the original exhaust.

Two of the three aftermarket products exceeded permitted noise limits for the Kawasaki 1000cc motorcycle and one was quieter than the original exhaust.

Next steps

At the time of writing, the results are being collated from the testing and we will follow up with manufacturers, retailers and approval authorities in 2024 to ensure that products are brought into compliance.

4. Tyre labelling

Aim of the programme

To test a range of new car tyres supplied into the market to ensure that tyre manufacturers assigned appropriate performance values to their tyres as rated on the tyre labels. The testing was conducted under Regulation (EU) 740/2020.

What we did

We tested a range of 10 different tyres of 3 tyre sizes, equating to 30 different types of tyres. This was against the 3 main performance parameters on the tyre labels:

• wet grip performance
• fuel efficiency (rolling resistance)
• noise levels

The 3 tyre sizes were chosen based on 3 different types of vehicle:

• 235/55 R18 - SUV tyre
• 255/35 R19 - high performance tyre
• 235/55 R17 - people carrier tyre

What we found

Of the 30 tyres tested, 20 failed to meet one or more of the values presented on the tyre label as declared by the manufacturers.

Regulations require that 3 further validation tests are conducted on each tyre for each parameter failed and the average values are taken to determine whether the tyre meets the parameters declared on the tyre label.

Due to 3 of the tyre models that failed being unavailable (ceased production) we were only able to retest 17 of the 20 failures. Of the 17 tested, the following results were found:

• 1 failed to meet all 3 parameter values declared on the tyre label
• 2 failed to meet the wet grip and noise values declared on the tyre labels
• 9 failed to meet the wet grip values declared on the tyre labels
• 1 failed to meet the noise value declared on the tyre label
• 4 met all the parameter values declared on the tyre labels

Where failures were encountered, we have contacted manufacturers seeking an explanation as to why, and this work is ongoing.

Next steps

We will continue this work into 2025 by testing popular tyre sizes from a range of different manufacturers against the same parameters (wet grip, noise and fuel efficiency).

5. Part-worn and re-treaded tyres

Aim of the programme

We checked whether part-worn tyres and re-treaded tyres supplied for vehicles under 3500kg complied with the Motor Vehicle Tyres (Safety) Regulations 1994.

Re-treaded tyres require relevant type approval to ensure they have been tested and are safe for use on a road.

What we did

We carried out mystery shopper exercises in 5 areas of the UK. Local trading standards officers accompanied 4 of these exercises. We visited 78 premises in total and test purchased 53 part-worn tyres.

We carried out open source research of 21 online suppliers of re-treaded tyres. Across the year we test purchased 8 re-treaded tyres.

What we found

Of the 53 part-worn tyres purchased during the mystery shopper exercises, an engineer inspected them and found 5 of them to be unroadworthy because:

• 1 had a metal screw penetrating the tyre
• 4 were deemed to have an unacceptable repair

Local trading standards officers are following up on these non-compliances and taking necessary action. The regulations require that part worn tyres are marked as such, however only 2 of the 53 tyres were marked ‘part worn’. These too were reported to local Trading Standards offices.

We sent a letter to the sellers of non-compliant tyres to remind them about their obligations.

Tyre age

The Tyre Safety Regulations do not stipulate a maximum tyre age, but as a general indicator we noted the number of tyres bought with date stamps indicating the tyre was more than 10 years old. Six of the part-worn tyres bought were found to be over 10 years old, with the oldest marked as week 38 of 2003 (over 19 years old).

The 8 re-treaded tyres purchased complied with regulations upon inspection.

Next steps

This programme will now be intelligence-led only. DVSA welcomes intelligence about part-worn and re-treaded tyres compliance. Should any non-compliance be found, this will be followed up with Trading Standards.

6. Motorcycle helmets and visors compliance

Aim of the programme

We checked the sale of motorcycle helmets and eye protection (visors and goggles) in the UK to ensure that they:

• meet the type approval requirements
• have the right certification markings as prescribed in the Motor Cycles (Protective Helmets) Regulations 1988 as amended
• meet legislative safety standards

What we did

We conducted broad market surveillance to identify different retailers and manufacturers of motorcycle helmets and visors available for sale in the UK through online platforms, industry events and in-store establishments.

We test purchased 23 different models and brands of motorcycle helmet and laboratory tested them to establish whether they meet the approval standards laid down in UNECE Regulation 22.05.

Helmets were selected from known industry risks and non-compliance identified in previous years’ programmes, as well as in conjunction with the Safety Helmet Assessment and Rating Programme (SHARP) and those not subject to testing under the SHARP programme, such as open-face helmets.

A minimum of 2 impact (linear) tests and one retention (chin-strap) test were conducted for each helmet model with the impact tests being carried out on 2 different sizes to establish fair results.

We test purchased 12 tinted visors from a range of online sources including retailer websites and online selling platforms. These were checked for approval and the correct markings.

What we found

Of the 23 motorcycle helmets:

• 17 were approved to UNECE Regulation 22.05 or UNECE Regulation 22.06
• 6 helmets were not approved but 5 of these were stickered as approved to ECE 22.05 and were sold as meeting ECE standards
• 1 was claimed to meet DOT (USA) standards

The test results were as follows:

• 9 approved helmets passed all 3 tests
• 2 approved helmets failed all 3 tests
• 4 non-approved helmets failed all 3 tests
• 1 approved helmet failed impact tests only
• 5 approved helmets failed the retention test only
• 2 non-approved helmets failed impact tests

Results by helmet type:

• 9 open-face helmets were tested - 7 of these failed one or more of the tests
• 9 full-face helmets were tested - 3 of these failed one or more of the tests
• 5 flip-front (modular) helmets were tested - 4 of these failed one or more of the tests

We retested 6 models to further validate the results of the initial tests. This was carried out on the recommendation of the test laboratory, in order to check an alternative size to verify that the results were fully representative of the model range, particularly where the helmet sizing was inexact. Five of the models retested were approved and one non-approved. Of the retested helmets, 5 failed the testing and 1 was deemed as a pass. These results are reflected in the numbers given above as the overall findings of the testing programme.

Of the 12 visors, 6 were found to have no approval markings in place, 1 was marked as not for road use and 5 were approved to the required standards. The non-compliant products have been followed up with the retailers and listings removed from online selling platforms.

Next steps

Eight approved helmets failed the testing to UNECE Regulation 22.05. We are following up with the manufacturers and retailers in the UK to have the products removed from sale. The approval authorities are also being informed to have the approval withdrawn for all of these products.

We have contacted online selling platforms regarding the non-approved products, particularly those being mis-sold as meeting the required safety standards. The products have been removed from sale.

7. Brake linings

Aim of the programme

We tested replacement brake linings for L-category vehicles (such as motorcycles, tricycles and light quadracycles) against legislative standards and checked the supply of aftermarket brake linings in the UK to make sure that they:

• met the type approval requirements
• had relevant markings
• met safety standards

What we did

This programme was split into 2 parts:

• testing L-category replacement brake linings
• checking type approval compliance

Testing

We identified and bought 5 mopeds deemed to be the most popular in use and to have a healthy aftermarket product availability.

• Honda PCX
• Sym Jet 14
• Peugeot Speedfight 5
• Yamaha Aerox
• Lexmoto Echo

For each moped we identified 3 different brands of brake linings to test for compliance. The brands tested included:

• RMS Motorcycle Parts
• Pagaishi
• EBC Brakes
• Brenta
• Polini
• Naraku
• MotorTech
• CA Moto
• VMP
• Lextek
• Gear
• Bendix

All 15 brake linings were tested against:

• dry stop - single brake control actuated
• dry stop - all service brake controls actuated
• high speed
• wet brake
• heat fade - prolonged and heavy braking

Although all tests were performed, not all are applicable as they are not mandated for motorcycles with certain engine capacities (50cc and 125cc).

Checking approval

We bought 55 brake linings across a range of manufacturers and distributors to check that they were sold in compliance with the type-approval requirements. This covered a range of vehicles including cars, vans, heavy goods vehicles (HGVs), campervans and bikes.

What we found

From the testing, we found all 15 brake linings to be compliant against legislative standards.

Our findings, from several test purchases in the approval checking part of the programme, identified errors and non-compliance by 4 manufacturers and distributors, all corresponding to L-category brake linings. Bendix, Pagaishi, Motor Tech and CA Moto were identified as supplying brake linings where no markings were present on the component.

All 4 manufacturers were reminded of their obligations and listings were removed from online platforms. Each has been reminded to ensure a vehicle, system, component, or separate technical unit, must bear the required statutory plate or type-approval mark before it is made available on the market.

Next steps

Due to the outcome of the approval checking and to ensure future compliance in the industry, we wrote out to all L-category brake lining suppliers and manufacturers based within the UK and those based outside selling to the UK.

This programme will now be intelligence-led only. DVSA welcomes intelligence about brake linings.

8. Advanced driver assistance systems (ADAS)

Aim of the programme

We checked that a type of advanced driver assistance system (ADAS), known as advanced emergency braking system (AEBS), was functioning correctly and compliant with regulations in commercial vehicles. Our aim was to check how systems functioned across the following 4 approval tests as required by UNECE regulation 131:

• warning and activation test with a stationary target
• warning and activation test with a moving target
• deactivation test
• false reaction test

What we did

We tested the AEBS fitted to 3 commercial vehicles with a gross weight of 18,000kg. The vehicles were:

• Mercedes Actros
• DAF LF260
• Iveco Eurocargo

We prepared the vehicles before testing. This included:

• a vehicle check to ensure each one was fit for test
• diagnostic scans to ensure advanced emergency braking associated parameters had no fault codes present
• being loaded to a DVSA specified test weight

What we found

For the 3 heavy goods vehicles tested under this year’s programme, the AEBS installed in all of the vehicles functioned as required across all 4 tests.

Each of the functional tests conducted were successfully completed and demonstrated compliance with the requirements set out by the regulations.

Next steps

We’ll continue to test advanced driver assistance systems programmes during 2024 and 2025. We will look to test passenger and light-goods vehicles (category M1 and N1).

9. Fitting and supply of defective or unsuitable vehicle parts

Aim of the programme

Some businesses openly offer services to alter vehicles through:

• engine emission alteration
• noise emission alteration
• window tinting

The programme’s objective was to ensure adherence to regulations regarding these vehicle modifications and the companies providing such services.

Businesses providing services to modify vehicles have an obligation under The Road Traffic Act 1988 and The Road Vehicles (Construction and Use) Regulations 1986 to ensure that the vehicle modifications being offered and carried out are lawful.

What we did

We concluded our investigations from 2023 into noise alteration services being offered, where 2 of the vehicles presented to garages as part of mystery shopper exercises were found to exceed the legal noise limit post modification. Onyx Performance Ltd and AET Motorsport Limited were found to be fitting unsuitable vehicle parts to vehicles in contravention of the Construction and Use requirements which would make them illegal to be used on a road. Both cases were referred for prosecution. The defendants pleaded guilty to the charges and Onyx Performance Ltd was fined a total of £5800 and AET Motorsport Limited was fined a total of £7234.

A significant outcome from the case of Onyx Performance Ltd highlighted that a disclaimer stating that a vehicle will not be used on the road is insufficient when garages modify vehicles. Garages must thoroughly explain any modifications to the customer and ensure the customer understands the implications of those changes. Moreover, the customer should be able to demonstrate how they plan to transport the vehicle safely once it has been modified, ensuring full compliance with any legal or safety standards.

We also conducted broad market surveillance through open-source research of businesses offering vehicle modification services including, but not limited to, ‘pop and bang’, catalytic converter removal, DPF and AdBlue delete or removal. We identified 111 businesses across the UK offering illegal modification services. Each business was sent a letter to remind them of their obligations as a vehicle modifier with links to online guidance, the relevant legislation, and a request to cease all illegal modifications.

Engagement with online selling platforms was undertaken along with representatives of aftermarket modification suppliers to improve the information to consumers. Specifically, to ensure that services and products are advertised properly, making it clear to the consumers at point of purchase what they can legally do.

Window tinting

We identified 684 businesses across the UK offering to fit and supply automotive window tints. Each business was sent a letter to remind them of their obligations as a vehicle modifier, the legal limits for window tinting, and the relevant legislation.

We purchased 42 window tint products including 15 ‘chameleon’ tints advertised for installation by the customer. Chameleon tints are a colour changing mirrored effect tint and were of particular interest due to their growing popularity and claims around meeting the legal limits even when applied to windscreens.

We carried out 2 mystery shopper exercises to investigate window tint services being offered, where we took a vehicle purchased or hired by DVSA along to a window tint service provider to have the windows tinted

In addition to the scheduled mystery shopper operations, we also investigated and prosecuted a window tint service provider based on intelligence we received. They advertised their services through social media, so they were contacted through Facebook. A DVSA vehicle was taken to a service provider and asked to provide a window tint on the front side windows of the vehicle.

We baseline tested the vehicle windows using calibrated equipment to establish visible light transmission values before any alterations were made to make sure the windows met the relevant approved standards. We also tested them after the alteration.

What we found

Of the 42 window tint products advertised for installation by the customer that were purchased:

• 25 had no information for customers on the current window tint regulations
• 8 provided partial legal information
• 9 provided customers with all relevant legal information

Of the 42 window tint products tested:

• 40 of the products were of the level of tint “as advertised” when tested on un-tinted glass
• 2 of the products were substantially darker than the advertised level of light transmission

Our investigation revealed that Robert Harding, trading as Storm Window Tinting, a supplier and fitter of window tints based in Thatcham, Berkshire, had knowingly illegally tinted a vehicles windows for road use. The case was referred for prosecution at Reading Magistrates’ Court. Mr Harding was successfully convicted by DVSA for fitting of unsuitable vehicle parts and fined a total of £1,444.

Window tinting mystery shop 1: traditional tint film

Window	VLT before modification	VLT after modification	Legal limit for VLT
Windscreen	82.5%	81.2% (no tint installed)	Minimum 75%
Front nearside window	81.6%	46.7%	Minimum 70%
Front offside window	81.9%	46.2%	Minimum 70%

Window tinting mystery shop 2: chameleon tint film

Window	VLT before modification	VLT after modification	Legal limit for VLT
Windscreen	81.9%	80.0%	Minimum 75%
Front nearside window	79.4%	77.0%	Minimum 70%
Front offside window	79.0%	77.5%	Minimum 70%

Whilst there were concerns around chameleon tints at the outset of the programme, the window tint service provider that installed the chameleon tint chose a very light tint to ensure that it complied with the legal limits for light transmission, showing that even though chameleon tints appear to obscure more light it is possible to install an appropriate film and keep the vehicle compliant.

Intelligence case

Window	VLT before modification	VLT after modification	Legal limit for VLT
Windscreen	Not tested	Not tested	Minimum 75%
Front nearside window	78.3%	46.1%	Minimum 70%
Front offside window	78.1%	45.5%	Minimum 70%

The service provider was interviewed and successfully prosecuted following these results.

Next steps

The investigation into the window tint service provider for mystery shopper 1 will be concluded and published in next financial year’s annual report as at the time of writing this case is progressing through prosecution.

We will continue to investigate defective or unsuitable vehicle parts being supplied during 2025.

10. Electrically assisted pedal cycles (EAPCs)

Aim of the programme

We checked the supply of electrically assisted pedal cycles (EAPCs) in the UK including suppliers providing a service to convert standard pedal cycles into electric bicycles using conversion kits to make sure that they’re either:

• compliant with the relevant regulations
• type approved to the required safety standards

What we did

We identified a total of 39 different retailers and manufacturers through online research, visiting events and shows, and conducting mystery shopper exercises to see if they were compliant with regulations.

A further 12 providers were identified through broad market surveillance as offering services to convert standard pedal cycles into electric bicycles through fitment of a conversion kit.

We carried out 18 mystery shopper exercises at 18 retailers in Great Britain (England, Scotland and Wales) to check what they were selling and if those products were compliant.

We also attended a live show event for electric vehicle and mobility products, featuring many manufacturers, retailers and suppliers of EAPC products.

What we found

We found that 21 of the 39 electric bicycle suppliers identified during broad market surveillance were selling electric bicycles that were compliant with the EAPC regulations.

During the mystery shopper exercises, we found that 2 were selling non-compliant electric bicycles for use on the roads. One of these brought their selling practices into compliance and the second supplier is being investigated further. At the live event one supplier openly claimed that one of the EAPCs on display could have the speed limit increased, exceeding that permitted by regulations. This was followed up with the company and their products and selling practices were brought into compliance. One supplier in Northern Ireland was advertising high-powered electric bikes and investigations will continue as part of the 2025 programme.

We wrote to the remaining 14 suppliers of high-powered electric bikes and explained the non-compliance. The response has been positive and they have withdrawn the non-compliant products from sale or changed their advertising to make it clear that they are not supplied for road use.

In addition, broad market surveillance was carried out to cover online selling platforms such as eBay and Amazon, to identify where high-powered electric bikes were being supplied into the UK market. Over 300 listings of non-compliant electric bikes being sold for road use were removed from Amazon. A further 132 separate listings for non-compliant electric bikes were removed from the eBay selling platform.

Of the service conversion providers, 5 were found to be offering services to convert bicycles into electric bikes that required type approval for road use. We wrote to all of these providers and gave them advice. All responded positively bringing their services and advertising into compliance.

Next steps

We’ll continue this programme into 2025. We’ll work alongside other government agencies, industry bodies and trade associations to influence and educate suppliers and end users to ensure compliance. This will include looking at suppliers of 2, 3 and 4 wheeled bikes and conversion kits.

We will continue to check the compliance of services to convert standard pedal cycles into electric bikes.

11. Electric and petrol-powered scooters

Aim of the programme

We carried out online open-source research and visited retailers, shows and events to investigate suppliers and manufacturers of petrol and electrically powered standing and seated scooters in the UK. We checked whether they are being sold in line with legislative restrictions.

Retailers must provide their customers with accurate information about the legal restrictions on petrol and e-scooter use. Failure to do so is an offence.

What we did

We conducted broad market surveillance and mystery shopper exercises across the UK by doing open-source online research and attending relevant industry events.

We identified 46 suppliers of e-scooters and checked their compliance against the regulations. Additionally, follow-up compliance checks were carried out on the 55 suppliers investigated as part of the 2023 programme to ensure the suppliers were continuing to provide correct information at the point of sale with no conflicting imagery or videos.

We carried out 21 mystery shopper visits to establishments selling e-scooters to check what information was being given to the public at the point of sale.

We carried out online mystery shopper exercises of 12 suppliers of petrol-powered scooters and checked their compliance against the regulations.

What we found

The findings from the programme revealed the following:

• 12 suppliers were correctly advertising e-scooters for private land use only
• 14 suppliers were advertising e-scooters for sale with a disclaimer present regarding riding on private land only - however, alongside the disclaimer they were openly displaying images and videos depicting road and pavement use and riding in public places, these suppliers were also using words that referred to “commuting”, “city use”, “getting around town” and other suggestions of riding on roads and public places
• 10 suppliers were advertising e-scooters for road use, riding on pavements and using in publicly accessible places, with no information on where privately owned e-scooters can be ridden

Open-source research was carried out into 12 suppliers of petrol-powered scooters. We found:

• 5 suppliers were correctly advertising petrol scooters for private land use only
• 1 supplier was advertising petrol scooters for sale with a disclaimer present regarding riding on private land only - however, alongside the disclaimer they were openly displaying images and videos depicting road and pavement use and riding in public places
• 3 suppliers were advertising petrol scooters for road use, riding on pavements and using in publicly accessible places, with no information on where privately owned petrol scooters can be ridden

Reminder of obligation letters were sent out to the 28 non-compliant suppliers reminding them of the current regulations around petrol and e-scooter use and advertising. Following the letters, positive changes have been noted across the industry with 26 suppliers removing all misleading imaging and advertising being removed, and providing the correct legal information to consumers.

We reported 2 suppliers of e-scooters that continued to ignore regulations and failed to engage with DVSA to the Advertising Standards Authority.

One further supplier identified as part of the 2023 programme failed to engage with DVSA or make any changes to their website and ran a non-approved e-scooter rental scheme. As a result, evidence was gathered to support criminal prosecution proceedings, and the company has now been reported to court.

We found that 18 of the 21 suppliers visited gave all the correct legal information at the point of sale. We contacted those that did not, reminding them of their obligations.

Next steps

Although there is still a degree of non-compliant advertising of private e-scooters, the overall response to advice and information from DVSA has largely been positive with suppliers making changes to their marketing.

We will continue with the broad market surveillance of the electric scooter market to ensure industry compliance.

We will also test certain e-scooters involved in government-approved rental schemes to determine compliance with the Vehicle Special Orders granted.

12. Small trailers

Aim of the programme

We checked suppliers selling small trailers in the UK to make sure that they:

• meet the type approval requirements
• have relevant markings
• meet safety standards

What we did

We carried out broad market surveillance through open-source research to identify businesses and individuals who supply small trailers.

We wrote to 70 small trailer suppliers across the UK as part of a desk-based assessment. We asked them to provide their approval documentation and details of the trailers they supplied.

What we found

Our investigation revealed that Mr Ifaquar Ali Shah, director of Beneto Italia Limited, had knowingly supplied small trailers illegally for road use. Mr Shah had failed to make records for supplying them between 21 May 2021 to 13 March 2023. Mr Shah was successfully convicted by DVSA for the supply of non-type approved trailers and received a total fine of £11,873.

A total of 5 trailer suppliers were identified for test purchasing to check compliance with road safety requirements and the regulations. We found that 3 of the trailers had no noted issues, One trailer was classified as agricultural and therefore exempt from the regulations. An investigation is currently ongoing into the remaining trailer supplier.

Following a mystery shopper exercise, our investigation revealed that Lizard Trailers (SW) Limited, a manufacturer and supplier of small trailers based in Cornwall, had knowingly supplied trailers illegally for road use for over the course of 10 years. The case was referred for prosecution at Bodmin Magistrates’ Court. Lizard Trailers (SW) Limited was successfully convicted by DVSA for the supply of non-type approved trailers and fined a total of £5569.

Next steps

We’ll continue our surveillance of suppliers of small trailers through intelligence received.

We have built strong stakeholder relationships with the trailer industry and continue to work closely with the National Towing and Trailers Association (NTTA) in reaching out to the industry to advise and educate through presentations and guidance in ensuring the industry is compliant.