GB Type Approval Scheme

This page was last updated on 3rd November 2022

GB Type Approval Scheme FAQs

Introduction

This frequently asked question (FAQ) page has been produced to address questions raised during communications events held by VCA to outline the structure and requirements of the GB Type Approval Scheme. The document will be updated in future to incorporate further questions or topics as required.

Some questions in the document relate to the UK(NI) type approval scheme or are applicable to both the GB and UK(NI) schemes. Answers are set out to make clear the requirements applicable to each scheme in these cases.

The questions addressed in this document have been grouped according to topic to aid navigation.

For any further questions not addressed below, please use the contact us page on the VCA website to submit queries such that they are routed and tracked appropriately.


Legislation

General

  • Have any technical requirements differing from the EU been implemented in the GB scheme?
    • The only technical change made to GB retained legislation to date is to remove the 4m height limit for vehicles. No other technical changes have been made to retained legislation for the purposes of GB type approval.
      There may be cases where EU legislation has been amended since being retained in GB law, resulting in technical differences between the two standards. In these cases, it is not anticipated that differences in legislation are likely to cause difficulty as vehicles/systems/components approved to later EU legislation are still likely to comply with GB requirements.
  • Is the use of km and km/h units in retained legislation considered a “deficiency” to be amended ahead of full GB scheme implementation?
    • No, The use of km and km/h units in legislation is not a deficiency. These units will be maintained in the GB scheme legislation.
  • Are there any changes to the Individual Vehicle Approval (IVA) scheme in the new GB type approval legislation?
    • No, IVA requirements are not impacted by the new GB type approval scheme.

Legislation Timing

  • When will the deficiency corrected versions of the legislation become available?
    • A final version of the legislation will be published on legislation.gov.uk once relevant parliamentary process has been completed and the new statutory instrument (SI) becomes law. This is anticipated to take place at the start of January 2023.
      A final draft version of the legislation will be available on legislation.gov.uk once SI has been presented to parliament for approval.
  • What is the timing of legislation relating to L, T and NRMM categories?
    • The provisional schemes for L and T category vehicles and engines for non-road mobile machinery will continue until the 31st December 2027 to provide more time to bring the full schemes for these categories into place.

Future Legislative Plans

  • Will there be a further consultation relating to plans for L, T and NRMM categories in future?
    • Yes, a consultation is planned to aid in the development of legislation relating to these categories.0
  • Will the General Safety Regulation II (GSRII) requirements be adopted into GB type approval?
    • GSRII legislation is not retained in UK law as it took effect after 31st December 2020. This means that GSRII does not form part of the GB type approval scheme and further legislation would be required should there be a decision to implement the associated requirements in future. No such decision has currently been taken, but the Department for Transport will work with industry to determine future plans for the GB type approval scheme in this and other subject areas.
  • Are there any plans to accept other global approval standards in future e.g. FMVSS?
    • There are no current plans to incorporate global standards other than UNECE into the GB type approval scheme.

GB Type Approval Application Process

  • Is it possible to apply for both a GB and UK(NI) approval for the same vehicle type?
    • Yes, a manufacturer may hold both GB and UK(NI) approvals for the same vehicle type as the approvals fall under different regulatory frameworks.
  • Do manufacturers require a representative based in GB or NI when applying for GB or UK(NI) type approval?
    • For GB type approvals, manufacturers based outside of GB must have a GB-based manufacturer’s representative. For UK(NI) type approvals, manufacturers based outside of NI or the EU must have an NI-based or EU-based manufacturer’s representative.
  • Can a manufacturer use EU system type approvals and test reports as part of a GB WVTA application, or do they need system approvals and test reports?
    • EU system approvals cannot be used as part of a GB WVTA application, only GB or UNECE system approvals are acceptable.
      Test reports will be accepted if they are from a Technical Service designated by VCA for GB Type Approval, or if they are from any EU-designated Technical Service during the initial Technical Service derogation period.
  • What do GB type approval information documents look like?
    • Templates for GB type approval information documents are as set out in retained EU legislation, either in individual regulations or the generic template in Regulation 2020/683.
  • Can an EU format information document be supplied for the purposes of a GB type approval application?
    • If the EU document has all the information required as part of the GB template, an EU information document can be accepted.
      If there are minor differences between a document already used for EU approval and subsequently supplied for GB approval (e.g., inclusion of a GB-base manufacturer’s representative), it is acceptable to supply the EU document with a cover page detailing the changes rather than producing an entirely new document.
  • Is it acceptable for documents and test reports to contain references to non-retained GSRII legislation?
    • Yes, information documents based on GSRII templates and test reports referencing GSRII legislation may be used in support of GB type approval applications if they contain all of the information and compliance evidence required by retained GB legislation.
  • How long will it take to receive a type approval certificate following application for full GB type approval?
    • VCA currently work to a timeline of four weeks for technical checks, followed by two weeks for administrative processes for an approval to be issued. This timeline will remain for GB type approval, though may be shorter as a result of efficiency gains from new processing systems.

Multi-Stage Approval Applications

  • Does a multi-stage manufacturer have to wait for stage 1 manufacturers to obtain full GB approvals before they start their own application?
    • Initially it will be possible for second stage manufacturers to obtain multi-stage approvals prior to base vehicle manufacturers obtaining full GB type approval to provide more flexibility during the transition to full GB approval. This derogation will last until 1st August 2026 for M and N category vehicles, and 1st August 2027 for O category vehicles.
  • In cases where the same manufacturer holds the incomplete and completed approvals, is full GB approval required for both stages?
    • Yes, the derogation referenced above does not apply in cases where both stages are approved by the same manufacturer as they are able to coordinate timelines accordingly.

Technical Services

  • Will VCA accept test reports from any Technical Service, or must they be a VCA designated Technical Service?
    • In future, all test reports used in support of GB type approval applications must be from a VCA designated Technical Service. There will be an initial derogation period during which reports from EU designated Technical Services may be accepted which will run until 31st December 2026 for M and N category vehicles, and 31st December 2027 for O category vehicles.
  • In the case where a GB approval is issued based on test reports from an EU Technical Service who are not designated after the derogation period ends, will the approval be withdrawn?
    • No, approvals will not automatically become invalid in cases such as this, and VCA will implement a process to ensure that a designated Technical Service can take on responsibility for the approval in the case of future changes.
  • Could VCA reject an application if they have an objection with the content of the EU Technical Service test report during the derogation period?
    • Yes, VCA have an option to accept reports from EU Technical Services during the derogation period, not an obligation. This means that VCA reserves the right to refuse an application in the case of any significant concerns or objections relating to the test report presented.
  • Do VCA intend to designate category C (CoP) Technical Services for the GB scheme?
    • No, VCA have no current plans to designate category C Technical Services, this will be a function retained by VCA’s internal Technical Services.
  • Will Article 72 (in-house Technical Service) provisions be maintained in the GB scheme?
    • Yes, there is no intention to remove these provisions from the GB scheme for the relevant subjects.

UNECE Type Approvals

  • Will UNECE type approvals still be accepted as part of the GB type approval scheme?
    • Yes, for subjects where equivalence of UNECE type approvals is recognised in respective type approval frameworks as retained in UK law.
  • Will additional UNECE regulations be recognised in the GB type approval scheme in future?
    • The intention is to maximise the use of UNECE regulations within GB type approval where possible. Once the necessary legislative powers are in place, we will look to expand formal equivalence lists within the respective type approval frameworks.
  • Will UNECE approved components require “g11” marking if used in the GB scheme?
    • No, UNECE approved components will be accepted at face value with no additional markings or documentation required.
  • Will additional GB Conformity of Production (CoP) be required in relation to UNECE approvals?
    • No, UNECE approvals will be accepted at face value and CoP will be managed by the UNECE Granting Type Approval Authority in these cases.

Conformity of Production (CoP)

Further information regarding CoP and FAQs from the GB CoP seminar and webinar events held in 2021 can be found here.

  • Can CoP clearance related to an EU type approval be used instead of additional GB CoP clearance?
    • No, GB CoP clearance is separate from EU CoP clearance as they relate to different type approval frameworks.
  • Can testing of EU type approved vehicles be utilised for GB CoP purposes?
    • Yes, where the vehicle specification and test procedures are common test date from EU type approved vehicles can be used in support of GB type approvals.
  • Will VCA have to conduct audits at manufacturer facilities where they have already been audited by an EU Technical Service?
    • Yes, VCA will conduct site audits irrespective of whether the site has already been audited by an EU Technical Service.
  • Does CoP clearance for UK(NI) type approval also cover GB type approval?
    • No, there are distinct requirements between UK(NI) type approval and GB type approval, so CoP clearance is separate for each scheme. However, VCA can make an assessment for both schemes as a single activity so there is no requirement for separate audits or applications to obtain both clearances.
  • Are there any new or different CoP requirements applying to GB medium series or small series type approval?
    • No, the requirements for these schemes are as defined in the retained legislation.

Certificates of Conformity (CoCs) & Approval Markings

  • Will the forthcoming update to EU CoC templates be reflected in the GB type approval scheme?
    • No. As the forthcoming changes to the EU CoC template do not constitute a legislative deficiency, they cannot be captured in the first SI, meaning that the EU and GB CoC templates will be different.
      However, a derogation will be implemented permitting the use of EU-format CoCs until the 1st July 2026 where the vehicle type concerned also holds EU type approval.
  • Will GB CoCs still contain reference to left/right-hand drive and metric/imperial units?
    • Yes, this aspect of the CoC format has not been changed so there is still reference to metric units and left-hand drive on GB CoCs.
  • Is it acceptable for GB approved vehicles or components to also be marked with EU type approval markings?
    • Yes, if the vehicle or component holds both EU and GB type approvals then dual marking is acceptable.
  • Can GB approval markings be placed on a label or sticker to avoid changes to tooling?
    • Requirements for the physical forms of markings are defined in individual regulations. Derogations on the implementation of GB approval markings will be applied for washer bottle and spray suppression components to allow sufficient lead time for tooling changes.

Environmental Approval Policies

Auxiliary & Base Emissions Strategy (AES/BES) Documents

  • Can an EU AES/BES document be used in support of a GB type approval application?
    • Yes, as long as the vehicle specification is common between the EU and GB type approvals and the EU document contains all items required by GB retained legislation.
  • Can the AES/BES audit process be aligned with CoP audits?
    • Yes, the timing of AES/BES audits can be determined according to manufacturer requirements as long as they are conducted with required frequency.
  • Will separate audits be required in relation to each separate AES/BES document approved?
    • No, the AES/BES audit will be a single annual review per manufacturer regardless of the number of AES/BES documents held. The duration of the audit may be longer or shorter depending on the number of documents held if more or less information needs to be reviewed.
  • What level of evidence is required to demonstrate that an EU Type Approval Authority or Technical Service has approved and AES/BES document?
    • Written evidence should be supplied, but this can take different forms depending on the arrangements between the manufacturer and Approval Authority or Technical Service in question.
  • Where will the AES/BES audit take place?
    • This can be determined by the manufacturer, but the location should be suitable in being able to provide the relevant contact personnel and information relating to technical and administrative questions relating to emissions strategy management.
  • Will additional AES/BES checks be required in the case that they are already covered as part of a UNECE type approval?
    • No, UNECE type approvals (including associated AES/BES reviews) will be accepted at face value in line with mutual recognition requirements.

In-Service Conformity (ISC)

  • Will VCA conduct Granting Type Approval Authority (GTAA) ISC testing separately from EU GTAAs?
    • Yes, as a separate GTAA granting approvals under a different legislative framework, VCA are obliged to conduct GTAA ISC testing in relation to g11 emissions approvals, regardless of whether GTAA ISC testing is conducted on equivalent vehicle specifications for the purposes of EU type approval.
  • How will transparency tables and warranty data be shared with VCA?
    • In future VCA intends for this functionality to form part of our digital type approval portal, but initially VCA will implement a temporary arrangement for data sharing and inform manufacturers of this when the data is requested each year.
  • Will in-service conformity testing also apply to heavy-duty vehicles and non-road mobile machinery (NRMM) engines in the GB scheme?
    • Yes, the obligations relating to in-service conformity or monitoring testing as set out in the relevant regulations will apply to these categories.
  • Can manufacturer ISC testing of EU vehicles be used to cover GB ISC obligations?
    • Yes, as long as the vehicle specification is common between the EU and GB type approvals then testing of EU vehicles can be used to cover GB manufacturer ISC obligations.

VECTO / Regulation 2017/2400

  • Are multi-stage manufacturers included in the scope of Regulation 2017/2400 in the GB scheme?
    • No, the retained legislation only applies to base vehicles.
  • Are trailers or buses included in the scope of Regulation 2017/2400 in the GB scheme?
    • No, only vehicles of category N3, or N2 vehicles with a technically permissible maximum laden mass exceeding 7500kg are within scope of the retained legislation.

Eco-Innovations

  • Can a GB approved Eco-Innovation be used in conjunction with a Provisional GB approval, or only a full GB approval?
    • GB Eco-Innovations can only be utilised within full GB approvals. Provisional approvals are based on underlying EU type approvals, so the EU approved Eco-Innovation referenced continues to be used in these cases.
  • Can an Eco-Innovation be approved for use in GB even if a similar application is rejected in the EU?
    • Yes, the decision on GB Eco-Innovations is independent from the decision on equivalent EU applications, though VCA will take account of any concerns raised in the assessment process.

Provisional GB Type Approval

  • Are there any GB statutory plate implications for manufacturers choosing to continue with Provisional GB approvals after the full GB scheme becomes available?
    • No, GB statutory plates are optional for vehicles covered under the Provisional approval scheme, even after the full GB scheme becomes available.
  • Is a GB manufacturer representative required for Provisional GB approval?
    • No, a manufacturer representative is not required for Provisional approval.
  • Can a manufacturer apply for a “new” Provisional approval before the 31st January 2024 deadline for currently approved vehicles in order to restart the two year validity period?
    • No, voluntary renewals of Provisional approval where there has been no change to the underlying EU type approval are not permitted. However, a manufacturer can apply for a new Provisional approval prior to the deadline if their current Provisional approval has expired, even in the event that there have been no changes to the underlying EU type approval.
  • Do Provisional approvals still have a two-year validity period once the full GB scheme becomes available?
    • Yes, every new Provisional approval will have a two-year validity period, regardless of when issued.
  • If vehicles are manufactured under a valid Provisional approval, can they be placed on the market at a later date even if it is after the deadline for full GB approval?
    • Yes, if the vehicle was manufactured when a valid Provisional approval was held, then it can be placed on the market on this basis even at a later date.
  • Where Provisional approvals remain valid in the event of changes to the underlying EU type approval (following the flowchart procedure), are they re-issued with a new two-year validity period?
    • No. It is not possible to issue new Provisional approvals after the respective deadlines pass and the flowchart procedure is implemented. This means that where there are changes in Provisional approvals after these dates, the two-year validity period is not renewed, but the Provisional approval maintains its original expiry date (i.e., two years from first issue).

Version 1.0
September 2022