Brexit: road, rail and maritime transport Contents

Chapter 5: Vehicle standards

Global standards

105.At the international level, standards for road vehicles are developed by the World Forum for Harmonization of Vehicle Regulations (WP.29), which sits within the United Nations Economic Commission for Europe (UNECE). WP.29 covers a range of vehicle design and manufacturing aspects, including safety, environmental performance, energy efficiency and anti-theft performance. It administers two UN agreements to which the individual EU Member States and the EU are all contracting parties in their own right.124

106.Mike Hawes, Chief Executive Officer, Society of Motor Manufacturers, told us that “different markets implement [UNECE regulations] to a greater or lesser extent”. He described the EU and the US as “the major regulatory powerhouse[s]”, and said that the EU was “hugely influential globally”, particularly on environmental and safety standards. Mr Hawes also told us that China’s environmental rules were generally based on EU standards.125

107.We note that the Government, in correspondence with the House of Commons European Scrutiny Committee in February 2018, indicated that “the EU generally persuades the UNECE to essentially copy EU-developed environmental regulations”, whereas for safety, “the process is more collaborative”.126

108.Mr Hawes said it was important that the UK should be “at the table” to influence the EU, as “the UK automotive sector … is different from just about any other Member State because we have a long tail of small, high-performance and luxury manufacturers”.127

109.On the other hand, Wincanton took the view that Brexit also presented an opportunity for the UK to “lead the industry in setting standards for new low-carbon and automated vehicles”, without “legacy restrictions from the EU in manufacturing and operation”.128

The Government’s position

110.When asked about the risk that the UK might lose its influence on global standards after Brexit, Mr Grayling took the position that “standards are now becoming more global than continental in nature”. He asserted that “the individual influence of the EU will diminish in this respect”, adding that “to a more substantial degree than ever, Asia is influencing these things”.129 The Secretary of State concluded: “We do not live in a world that is dominated just by the EU. We will be part of global forums that influence and shape.”130

111.The Secretary of State told us that the EU’s influence in global standard-setting was waning, but other witnesses suggested that the EU was hugely influential. If the latter is and remains true, the UK will have a continuing interest in the EU’s position on standards, which will be more difficult to influence after Brexit. Nevertheless, there may be opportunities, for example, in areas relating to newer technologies, for the UK to take a leading role in international standard-setting after Brexit.

Vehicle type-approvals

112.Type-approvals are issued by designated national authorities—in the UK, the Vehicle Certification Agency (VCA)—to certify that vehicles and vehicle parts meet specified performance standards. The UN 1958 Agreement on vehicle standards makes some provisions for mutual recognition of type-approvals for systems, parts and equipment among its contracting parties, but does not extend to whole vehicles. In the EU, vehicles can only be registered, sold and enter into service if they are manufactured in accordance with an EU type-approval issued by an EU type-approval authority. EU type-approval authorities may also act as ‘technical services’ for other national type-approval authorities, conducting tests and inspections on their behalf.131 EU type approval legislation also applies to non-EU EEA countries.

Future arrangements

113.The Government’s White Paper showcased the “mutual recognition of vehicle type approvals” as an example of the benefits of the common rulebook for goods. It also proposed mutual recognition arrangements for type-approval authorities and technical service providers.132

114.FTA noted that “for many safety features, current type-approval technical requirements are … based on UN regulations. However, even a global standard needs to be complemented with a sensible [whole vehicle] type-approval recognition scheme”. The FTA made clear that without an agreement, “type-approval certificates issued by the VCA would no longer be considered valid in the EU”.133

115.Mr Hawes explored the implications of a manufacturer requiring separate type-approvals for the UK and EU:

“Even assuming that the regulations we are type approving to are identical, which we hope will be the case, we would still have to go through two tests. As it is, a manufacturer based in Europe … has to design and engineer a vehicle for the UK with a steering wheel on the other side. That is an additional cost. If you have the additional burden of testing, which is not cheap, you are adding cost. If it is a small volume model, you will ask whether it is worth putting that car on to the market in the UK. If you say no, it could lead to a drop in consumer choice.”134

116.We note that the Government has previously indicated that the EU already recognises Swiss type-approvals, which are issued “to EU standards”.135 Mr Hawes described those arrangements as “exceptional”, since “Switzerland does not have a car manufacturing sector, so it is a matter of allowing vehicles to come into Switzerland rather than going the other way. We need something that is bilateral, and that is a greater problem.”136

The Government’s position

117.The Government’s written submission did not discuss the mutual recognition of whole vehicle type-approvals, but did make reference to the international framework for setting type-approval standards. The Government explained that “vehicle type-approval safety regulations are … developed internationally” within UNECE. It argued that through membership of UNECE the UK would be able to promote “harmonised international requirements”, and “ensure UN regulations do not restrict the implementation of new vehicle technologies”.137

118.For vehicles to be registered, sold and enter into service, they must be type-approved by a recognised authority. Failure to reach a future arrangement on mutual recognition for type-approvals would mean that two separate approvals would be required for vehicles entering the UK and the EU. This would have cost implications for manufacturers. We support the Government’s intention to seek mutual recognition of type-approvals as a mutually beneficial arrangement. We note, however, that there is no exact precedent for such a regime.


124 The list of contracting parties to the 1958 Agreement is available at http://www.unece.org/trans/maps/un-transport-agreements-and-conventions-18.html [accessed 7 May 2019]. Contracting parties to the 1998 Agreement are listed here: http://www.unece.org/trans/maps/un-transport-agreements-and-conventions-20.html [accessed 7 May 2019].

125 Q 45 (Mike Hawes)

126 Letter from Jesse Norman MP, Parliamentary Under Secretary of State, to Sir William Cash MP, Chairman of the House of Commons European Scrutiny Committee (6 February 2018): http://europeanmemoranda.cabinetoffice.gov.uk/files/2018/02/Sir_William_Cash_-_Vehicle_Type_Approval.pdf [accessed 18 December 2018]

127 Q 45 (Mike Hawes)

128 Written evidence from Wincanton PLC (TRA0013)

129 Q 64 (Chris Grayling MP)

130 Ibid.

131 Directive 2007/46/EC of 5 September 2007 establishing a framework for the approval of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles, OJ L 263/1 (9 October 2007)

132 HM Government, The future relationship between the United Kingdom and the European Union, Cm 9593, July 2018, p 21: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/725288/The_future_relationship_between_the_United_Kingdom_and_the_European_Union.pdf [accessed 13 December 2018]

133 Written evidence from the Freight Transport Association (TRA0017)

134 43 (Mike Hawes)

135 Letter from Jesse Norman MP, Parliamentary Under Secretary of State, to Sir William Cash MP, Chairman of the House of Commons European Scrutiny Committee (6 February 2018): http://europeanmemoranda.cabinetoffice.gov.uk/files/2018/02/Sir_William_Cash_-_Vehicle_Type_Approval.pdf [accessed 18 December 2018]

136 Q 44 (Mike Hawes)

137 Written evidence from the Department for Transport (TRA0012)




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