Manufacturers and funders need to be
prepared for European whole vehicle type approval, says

Philip Alton

EU whole vehicle type approval is being
introduced in stages until October 2014. These new regulations
apply to almost all vehicles and, for the first time, will cover
the entire vehicle, including bodywork and trailers. 

Type approval is confirmation that a vehicle
design meets performance standards. In the UK, approval is given by
the Vehicle Certification Agency, an executive agency of the
Department for Transport. Cars and motorcycles, minibuses, buses
and coaches are already covered. 

EC whole vehicle type approval covers 42
requirements which extend not only to the vehicle’s chassis and cab
but also the bodywork. Most of these requirements will fall to the
vehicle manufacturer but up to six areas will apply to

While in some cases, the current regime may run
in tandem with the new one, businesses should be gearing up to
comply with the new rules. The main implications are:

  • Funders will need to take more care when asked
    to fund a vehicle that is not road-registered.
  • The funding of incomplete vehicles will carry
    greater pitfalls. 
  • Manufacturers and suppliers need to ensure
    their contract terms are robust to avoid potentially complex
    disputes as to responsibility for obtaining type approval.
  • Care is needed with modifications to new
    vehicles to avoid the risk of infringing an existing type

Bodybuilders will need to get type approval for

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The implications of the changes are
far-reaching, and I would advise lessors to ensure that they are
well prepared to deal with them.

Changes to vehicle type approval regulation
Philip Alton is a partner at law firm