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Freshfields Risk & Compliance

| 3 minutes read

UK Department for Transport proposes extensions to GB vehicle type approval regime

In a consultation published last week, the UK Department for Transport (DfT) is seeking limited views on a proposed extension to the GB vehicle type approval scheme which would permit vehicles certified to the UNECE “Euro 6e” international standard to receive a GB type approval. Currently, the GB type approval scheme requires vehicles to be tested to the “Euro 6d” standard. The Government explains that this proposal would reduce the “complexity faced by manufacturers” in testing vehicles against national standards and would result in cost savings for vehicle manufacturing by removing the need for “double testing” and enabling “economies of scale.” In reality, this change would simply ensure that the UK aligns with the position in the EU and remedy the issue whereby the GB system is frozen as at the point when the UK left the EU. Euro 6e has been available for use to manufacturers in the EU for new type approvals since March 2023 and has been mandatory for new type approvals since September 2023. The European requirements, including Euro 6e, also apply in Northern Ireland pursuant to the Windsor Framework. 

Alongside these proposed amends, the DfT has also suggested some other smaller amendments, detailed below.  

Euro 6e

Euro 6e has a variety of substages, the first of which the DfT appears to be focusing on in its consultation. At a European level, the first step of Euro 6e amends the vehicle type approval testing procedure by reducing the Portable Emissions Measuring System (PEMS) margin for real-drive emissions tests (RDE).  The first step of Euro 6e also requires heavy vans to comply with the on-board fuel and energy consumption monitoring standards that already apply to cars and light vans. The later stages of Euro 6e (known as Euro 6e “bis” and “FCM”) will extend the normal and extended temperature ranges of the RDE test and increase the plug-in hybrid electric vehicle utility factor reference distance. Euro 6e also introduces some clarifications to the wording of the RDE and Worldwide Harmonized Light Vehicles Test Procedure (WLTP) testing procedures and adds some new provisions on in-service conformity checks by third parties.  

Euro 6e has been available for use to manufacturers in Europe for new type approvals since March 2023 and has been mandatory for new type approvals since September 2023. All new vehicles must comply with Euro 6e by September 2024 (excluding end-of-series exempt vehicles). In practical terms, if the DfT’s proposed amends are accepted, then manufacturers will be able to sell Euro 6e compliant vehicles across the EU and UK without having to retest vehicles to the older Euro 6d standard for the UK market. 

While not specifically referenced in the consultation, it seems possible that manufacturers faced with European countries no longer accepting Euro 6d vehicles will seek to sell older stock in Great Britain. The DfT has explained in the consultation that the sale of Euro 6d vehicles can continue in the UK “until further notice” but note that future emissions requirements for vehicles being sold in Great Britain are “being assessed”.  

Other proposals 

Alongside the alignment on Euro 6e the DfT is also proposing other smaller amendments to the GB scheme. These are: 

  • An update to retained Regulation 2018/858 to correct errors in the drafting of legislation when cross referring to international vehicle standards (the UNECE Regulations).  
  • Including references in the GB approval scheme to the materially identical international UNECE tyre requirements. 
  • Adding the UNECE regulation of electric vehicle special sounds (i.e. the noise made by electric vehicles to alert pedestrians of their presence) to the GB approval scheme.  
  • Accepting vehicles that meet the EU, rather than UK, specification for rear registration plate space. 

The DfT also envisages seeking further views in a later consultation regarding possible acceptance of international testing according to alternative standards, in relation to additional subjects where the DfT is confident that the impact on safety or the environment is “limited or non-existent”.

Next steps 

The questions posed by the DfT in the consultation are straightforward; they essentially ask whether the respondent has any comments on the acceptance of the new proposed standards. The consultation window is short (less than a month) and Respondents must submit views by 10 November 2023. As these proposals show that the UK is playing catch-up with reforms already introduced by the EU, we would anticipate that the proposals will be approved, and the associated legislative changes will be made relatively quickly.



automotive, brexit, infrastructure and transport