Haulage Permits and Trailer Registration Bill [Lords]

Written evidence submitted by The Road Haulage Association (HPTRB03)

Permit and Trailer Registration Bill

Dear Committee,

1. The membership of the RHA is a major stakeholder in respect to the Permit and Trailer Registration Bill. We represent the UK Commercial Road Haulage industry and the overwhelming majority of the UK road haulage operators working internationally will be in our membership. Our 7,000 plus membership operates about 250,000 vehicles, they range in size from large logistics companies with thousands of vehicles through to members with a single vehicle.

2. The Bill is of critical importance to our membership undertaking international operations.

3. The key points are:-

· The Bill is vital for the international road haulage sector.

· The Bill needs to remain focussed on its two primary objectives – the facilitation of permit allocation, if needed, after UK exit from the EU and the registration of UK trailers operating in international road haulage.

· The charges for permits, if required, should be based on cost recovery only.

4. The detailed RHA response is broken down into two parts to reflect the two parts of the Bill. To be clear, the RHA strongly supports the purpose of the Bill in both its elements.

5. The Permit element of the Bill is essential as it will allow the UK Government to allocate and administer new permit arrangements – should they be needed – once the UK leaves the EU.

6. The RHA is very clear about what it wants for our members, that is a simple system that will allow UK operators to move goods internationally to, from and through EU countries using a single permit or licence – much in the way of the current community licence. (As a quid pro quo, we also support the continued use of the EU Community Licence for non-UK operators from the EU to be able to move goods internationally to, from and through the UK). This approach will be simple for UK operators and will result in no additional burden at all in international road haulage for EU operators. The Bill allows for this outcome.

7. We strongly urge the UK Government to focus on delivering this type of simple comprehensive agreement during negotiations – we would like the Government to clearly state that this is the preferred solution for our sector.

8. We recognise that in seeking agreement with the EU that this simple, clear and fair approach may not be agreed during the negotiation, and that a system of individual bilateral permits may arise. This is not ideal, but should be workable with the right arrangements in place. The Bill allows for this outcome - it provides us with the ability to quickly put in place the arrangements required and gives a level of reassurance and comfort to the sector regarding future market access. Given there is a risk that 27 new separate bilateral arrangements might need to be put in place we need the framework the Bill provides.

9. While not part of the Bill consideration, we would like to take this opportunity to highlight again some key features we would like to see agreed if bilateral agreements do become required. Firstly, transit through EU Member States without separate transit permits will be essential. Secondly, there must be no quota limitation on the number of permits that may be issued under any bilateral or transit arrangements. Thirdly, permits should allow UK operators to move goods between EU Member States after entering the EU with an international load (an operator would need an international permit for both Member States to do this). Most lorries working internationally by 2019 will be Euro VI, we would not recommend bringing Euro Standards into any permits systems as this adds complexity.

10. If UK operators need to fall back onto use of ECMT permits for some or all journeys into or through the EU then the Government needs to be able to put in place systems for allocation of such permits. The Bill facilitates this.

11. The Permit part of the Bill should not do any more that facilitate the outcome of the negotiations in relation to market access for operators. Attaching other matters to the Bill or limiting the ability of the Government to put in place systems quickly should be resisted.

12. On trailer registration the RHA view is supportive of the mandating of trailer registration for large UK trailers moving internationally. There have been issues in the past with the movement of UK trailers in the EU as a consequence of UK trailers not being registered, this has added bureaucracy for operators in the past. Registration will avoid this and is welcome. We also support voluntary registration of all large trailers should the owners wish them to be registered. This provides flexibility without the need to commit to using them internationally.

13. In both cases, the RHA believes that any charges relating to trailer registration or issue of permits to be based on a cost recovery basis only.

14. Thank you for considering our evidence. Should you wish to engage with the Road Haulage Association, as the key trade body representing the commercial road haulage industry, please do not hesitate to contact me.

May 2018


Prepared 21st May 2018