National Type Approval in the UKThis page was last updated on 10th September 2021
This guidance is aimed at manufacturers or importers wishing to sell vehicles, and/or systems and components into Great Britain (GB) and Northern Ireland (NI).
In the United Kingdom, there are separate provisions for Great Britain and Northern Ireland as a result of the terms of the Northern Ireland Protocol. Under these terms Northern Ireland remains subject to EU type approval regulations, the approvals will be known as UK(NI) to distinguish them from EU member States’ approvals.
The UK type approval regulations cover both Great Britain and Northern Ireland but apply differently in each.
The regulations are;
- The Road Vehicles (Approval) Regulations 2020 (Statutory Instrument 2020 No. 818 (as amended)).
- The Motorcycles (Type-Approval) Regulations 2018
- The Agricultural and Forestry Vehicles (Type-Approval) Regulations 2018
New type approvals are available for all categories of vehicles under these national regulations – in conjunction with;
1) retained EU legislation in the case of GB approvals, or
2) directly applicable EU Regulations in the case of UK(NI) approvals.
Existing VCA approvals will be treated as UK(NI) approvals under the same legislation going forward, although it will be possible for holders of these existing approvals to request a GB approval for the same type – which will be considered an existing type.
These approvals have different validity;
- Vehicles with UK(NI) approval can currently be distributed in the whole of the UK
- Vehicles with GB approval can be distributed in GB only
VCA continues to operate as the United Kingdom Type Approval Authority under the two legal regimes that apply in Great Britain and Northern Ireland and can issue certificates under each. (The location of a manufacturer does not affect their eligibility for either scheme).
What kinds of scheme are available?
Whole Vehicle Type Approval (WVTA) is for manufacturers selling larger volumes and capable of meeting the full GB specifications or full EU specifications for Northern Ireland.
Some manufacturers of specialist cars or light goods vehicles who find some elements of the full type approval specifications too costly may benefit from using the Small Series (1500) scheme which allows production of 1500 vehicles per type (available for categories M1 and N1 only).
National Small Series (NSSTA) is for those who produce modest numbers of vehicles.
The key advantages of the NSSTA schemes is that demonstrating compliance with some technical requirements is simplified, which will have an impact on the costs associated with the approval process, and the Conformity of Production (CoP) requirements will be appropriate and proportionate to the scale of your operation. However, you will be limited to the number of vehicles you can manufacture in a given calendar year, and the restrictions of the geographic cover of the approval: i.e. GB only, for GB approvals, or both GB and Northern Ireland for UK(NI) approvals.
Which approval should I go for – UK(NI) or GB?
If you hold a WVTA issued by an EU-27 Member State or EU Small Series Type approval, then you can use that in Northern Ireland, but not in GB. So, in this case you should apply to VCA for Provisional GB Type Approval to enable vehicle sales in GB. However, EU type approvals for category O (trailers) will be accepted in GB until the provisional scheme comes into force for that category.
Manufacturers in Northern Ireland may also be able to use their EU type approvals to sell into Great Britain if their products qualify for unfettered access.
For manufacturers not holding an EU type approval, you should consider the kind of approval that suits your business. Currently a UK(NI) approval will allow you to sell into both GB and NI. Some manufacturers might also need a GB approval, for example if the production volumes permitted under the UK(NI) NSSTA scheme are insufficient or if you produce vehicles over 4m height. If you are certain that you only wish to sell vehicles in Great Britain, then GB approval alone may be suitable.
UK(NI) approvals continue to follow EU rules and so manufacturers should have a representative based in the EU or Northern Ireland. You will need to organise a representative in Northern Ireland or in the EU as soon as possible, unless you are already based there.
If you do not intend to sell in Northern Ireland, and/or do not have a suitable representative based there, then GB approval would be the most appropriate route.
What about Certificate of Conformity (CoC) and Vehicle Markings?
If you have an n11, g11 or e11 (which has not been transferred to another EU Authority) approval, the approval number should appear on the relevant UK(NI), GB or EU Certificate of Conformity (CoC) and be marked on the vehicle. The statutory (VIN) plate should contain the same number. From 1 January 2022, this will be checked at extensions or during CoP audits. Prior to this date, it is acceptable to continue to issue the EU CoC and have the EU (e11) approval number on the VIN plate, as long as records are kept linking VIN number to the correct form of approval (UK(NI) or GB).
If your approval was converted to another EU Type Approval Authority following the exit of the UK from the European Union, the previous e11 approval number no longer exists, and no products should be marked as e11.
The Provisional GB Type Approval number (for those manufacturers holding EU type approval from an EU-27 authority) does not need to be marked on a vehicle or CoC, although this is permitted. The Department for Transport (DfT) will be consulting on proposals to require markings in the future.
Vehicle Systems, Components and Separate Technical Units
Until the relevant into force date for the Provisional Scheme, EU approvals for vehicle systems, components, NRMM and separate technical units will continue to be valid across UK and so, currently, there are no requirements to obtain UK National Type Approval for vehicle systems, components, and separate technical units. However, the UK(NI) versions of these approvals are available upon request.