UK(NI) Type Approval Scheme – Frequently Asked QuestionsThis page was last updated on 30th September 2021
This guidance is intended for manufacturers, importers and distributors of motor vehicles in the United Kingdom.
One of the options for registering vehicles in the United Kingdom is now the UK(NI) Type Approval Scheme. This has been in place since 1st January 2021. The following is a selection of the most common questions asked:
What is a retained e11 approval?
If you did not transfer your e11 approval to an EU member state prior to the 1st January 2021, then it would have been automatically converted to a UK(NI) approval. This currently permits products to continue to be sold throughout the UK, however they can no longer be sold into the EU.
If you are in this group, your approval could be in the format:
e11*2007/46*????, e11*NKS*????, e11*KS07/46*????, e11*KS18/858*?????, Or e11*NKS18/858*?????
What are my options with my retained e11 approval?
If you wish to keep it as an UK(NI) approval, then you do not need to let us know. At the next extension we will update the approval to indicate it is following the UK(NI) requirements. This may result in issuing a revised approval number in the format n11* to indicate it as such, as detailed below. As a transitional measure, it will be acceptable to use the previous e11 approval number on any statutory markings until 1st January 2023, as long as the e11 marking represents an UK(NI) approval.
If you wish to reclassify it as a GB approval, then you should get in touch with your usual contact here at VCA and request this to be done. This request will be an internal VCA amendment only. At the next extension, the approval will be revised to indicate it is following the GB requirements and this will require a new g11 approval number to be issued. This will be a new approval number based on the next sequential number available.
If you wish to hold both GB and UK(NI) approvals, then the e11 can be retained as a UK(NI) approval and an additional GB approval can be created with a g11 approval number. These numbers will be different. The creation of the additional GB approval will be considered an existing Type with respect to Whole Vehicle Type Approval requirements and not subject to any new type requirements. For example, if you hold an e11*NKS*???? approval number then this will allow the creation of a g11*NKS*???? GB approval with the same content, as opposed to creating a number in the form g11*NKS18/858*?????. A new information document will be required and contain the GB legislation as the application scope.
A retained e11 approval which was previously EU Small Series (KS Approval Characters) will be considered as UK(NI) “EU Small series”. If wished, this can be converted into the GB equivalent, which is to be known as GB Medium Series approval with the same 1500 limit, under the same logic as above, in other words it is not deemed a new type but a continuation of the existing approval.
When do I need to decide?
If you want your e11 to be considered a GB approval, you should contact us as soon as possible. You will also need to ensure you have the correct representative for the approval type, otherwise no action is needed until the next planned extension.
What is the difference between a UK(NI) approval and a GB approval?
A UK(NI) approval is valid in Northern Ireland and currently also accepted in Great Britain. 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. From 1st January 2022, this will be a condition of VCA issuing extensions or revisions to your approval, and from that date this will be checked during Conformity of Production audits.
A new or extended UK(NI) approval will be in the format n11*2007/46*????
The GB Scheme is the new Type Approval scheme for Great Britain. This will replace the provisional GB scheme and is initially based on retained EU legislation as it applied in GB at the end of 2020. 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. A GB WVTA has no 4m height limit, and the GB National Small Series Type Approval (has higher numerical limits for the 2021 calendar year. A GB approval is valid in Great Britain and approval holders are required to have a representative based in Great Britain as soon as possible, if you are not based there. From 1st January 2022 this will be checked during extensions and at Conformity of Production audits.
A new or reclassified GB approval will be in a format such as g11*2007/46*????
A representative could be the approval holder or an additional third-party representative if the approval holder is not based in the required country. The obligations on the representative where they are a third-party are set out in Article 15 of EU regulation 2018/858 as retained in the UK.
Can I Hold Multiple Approvals?
Yes. You can hold UK(NI) and GB approvals for the same Type. It is also possible to hold a European Whole Vehicle Type Approval (Full Series) from EU or UK(NI) in combination with UK(NI) Small Series approval, or similarly GB WVTA in combination with GB Small series. It is not permissible to hold UK(NI) full series approval in combination with a European WVTA for the same Type.
How does the Northern Ireland Unfettered Access Impact me?
A qualifying Northern Ireland good can be imported to Great Britain using an EU approval without any additional requirements. In this situation the importer takes on legal responsibility for the product if there is no presence of the manufacturer in Great Britain.
Does this impact my Conformity of Production (CoP)?
Yes, you will need to update your CoP clearance scope in relation to your decisions and we will be required to hold a suitable representative in the applicable jurisdiction for the type(s) of approvals you have.
What records do I need to keep?
If you have a combination of GB and UK(NI) vehicles you are required to keep VIN records and production volumes intended for each market against the appropriate limits, if small series approvals are held.
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 Jan 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.
Do I need to use the UK(NI) Label?
Manufacturers using retained e11 or n11 UK(NI) approvals in full or “EU Small Series” (KS) are required to place a UK(NI) label next to the statutory markings (VIN plate or component approval mark) if they intend to place the product on the market in Northern Ireland.
This is not required if using a n11 UK(NI) national small series approval number (NKS) to place the products on the market.
Is Heavy-Duty Emissions Step E required to register a vehicle in Northern Ireland?
Yes, UK(NI) requirements align with that of the European Union, and so the implementation date of 1st January 2022 for registrations also applies in Northern Ireland.
Do you have a question not listed above? Then please get in touch.?
If you have worked with us before, you should reach out to your usual contact. Alternatively, you can send your enquiry to us, using our Contact Us page. Please include ‘GB Type Approval’ in the subject line to ensure your email is directed to the correct team.