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1,257 Posts
Discussion Starter #1 (Edited)
This is the response from DVLA to Jurasik's enquiry into changing his T4's registration details from Diesel Car to Light Goods Vehicle...

"All vehicle licensing and registration in the UK is governed by the Vehicle Excise and Registration Act 1994 (as amended) (VERA).

Before vehicles are first registered in the UK, DVLA is required to ensure that a vehicle has evidence of type approval, or is exempt from type approval. This information may be in the form of National Type Approval, European Community Whole Vehicle Type Approval, or confirmation that a vehicle meets certain domestic or European legislative requirements. Type approval ensures that vehicles, their systems and components, meet the appropriate environmental and safety standards for the appropriate vehicle category. The vehicle manufacturer applies to the Vehicle Certification Agency (VCA) for the type approval category relevant to the design style of their vehicle. This information is submitted with the application to first licence and register the vehicle.

In this particular instance the manufacturer applied, and attained, type approval in the appropriate category for the vehicles engine size, construction, weight and speed, in this case M1, which is described in the type approval regulations as a light passenger vehicle (i.e. a vehicle with at least 4 wheels used for the carriage of passengers and compromising no more than eight seats in addition to the driver's seat, having a mass not exceeding 3.5 tonnes). As this vehicle was presented for registration on the basis of having been type approved in the M1 category, with a CO2 emissions figure specified in terms of grams per kilometre, it falls to be licensed in the Graduated VED scheme paying duty according to it's CO2 figure and the type of fuel used.

DVLA is required to register a vehicle based on the evidence presented at first registration and is unable by law to change the type approval category once the vehicle has been correctly registered."

Before a vehicle can be put on the market anywhere in the world it has to meet the criteria for each country it is to be sold in by way of Type Approval.

What Is Type Approval?

The United Nations is currently attempting to standardise international Type Approval directives to a common standard, so new vehicles produced anywhere in the world can be sold anywhere in the world. Vehicle manufacturing is key to a country's success, and VW has played a key role in the fortunes of many countries over the years. However, a Type 2 made in Brazil, for instance, has to undergo a number of modifications before it can be sold in the United Kingdom (and the same is true for any vehicle brought in from outside the EU).

On the back of the UN initiative there is currently a new EU Type Approval directive being tabled - an update of the European Community Whole Vehicle Type Approval (ECWVTA). This Directive is designed to harmonise all type approval schemes, even the local SVA/LVTA/TUV type tests, across Europe, so each vehicle and each component fitted to a vehicle has to be fit for purpose. By tidying up these annomolies this new directive will allow for each certificated vehicle type to be sold anywhere, not just the country it was approved in.

Adaptations To Existing Vehicles

Volkswagen Partner companies such as Auto Sleepers have complied European Type Approval for some time. Yet it is the diversity of small businesses that specialize in this market sector that has delayed the implementation of this "whole vehicle" legislation for Motor Caravans in Group M1, although it does apply to everything else.

An array of adaptations can be made to a vehicle after manufacture to fulfil specific needs in the marketplace - even involving an entirely new floor and chassis suitably strengthened for harnesses to restrain wheel chairs and occupants, for instance. These could only be sold in the UK with either:
  • Single Vehicle Type Approval (SVA)
  • Low Volume Vehicle Type Approval (LVTA - for up to 500 units sold annually)
  • Wheel Chair Vehicle Converters Association approval (voluntary).
The UN's efforts would mean that these vehicles could be exported anywhere...

Only SVA and LVTA UK certificated conversions received Motability and Volkswagen Compatible Design approval. (The model shown here is an Auto Sleeper Trooper with suitable adaptations.)

These tests also applied to Crew Van, minibus and emergency vehicle conversions built by Volkswagen Partner companies, and Motor Caravan converters as already mentioned.

T4 Type Codes

Rather than test each of the 350 individual model types that emerged from Hanover and Poznan, the T4 range, as an example, is grouped together into similar model types, so over the course of the T4's lifetime the Type Approval process only took place when major modifications were made, for instance when the T4a grew into the T4b.

Panel Van (Kasten)

With no provision for rear seat belts

swb T4a – 70A / T4b – 7DA
  • 800kg (inc 800 and 888 Specials – UK only option pack Z49)
  • 1000kg, 1200kg
lwb T4a – 70H / T4b – 7DH
  • 1000kg, 1200kg
  • standard height or Hi-Top (with full height twin rear "barn" doors and single side door only)
Window Van (Kombi) including Motor Caravan (Campmobile) bases

With or without windows and seats but with provision for 3-way inertia seat belts in the rear quarters (vans do not have upper seat belt points in the rear)

swb T4a – 70B / T4b – 7DB
  • 800kg, 1000kg, 1200kg
lwb T4a – 70J / T4b – 7DJ
  • 1000kg, 1200kg
  • standard height or Hi-Top (with full height twin rear "barn" doors single side door only)
Bus (Caravelle / Eurovan) including Motor Caravan (Campmobile / Campingcar) bases

swb T4a – 70C / T4b – 7DC
  • Caravelle C, CL, GL, Multivan up to 1996
  • Eurovan CL, GL, MV (Multivan) , MV Weekender up to 1996
  • Caravelle Sedan, Variant, Limousine, Business, Multivan 1996 on
  • Eurovan MV Weekender 1996 on, GLS 2000 on
lwb T4a – 70K / T4b – 7DK
  • Caravelle C, CL up to 1998, Sedan 1998 on
Chassis Cab (Pritsche) including Pick-up and Powercab options for special bodies

swb T4a – 70E / T4b – 7DE
  • 1000kg or 1200kg
lwb T4a – 70L / T4b – 7DL
  • 1000kg or 1200kg
Double Cab (Doppelkab) including Pick-up and Powercab options for special bodies

lwb T4a – 70M / T4b – 7DM
  • 1000kg only
Going by DVLA's answer to Jurassik's question Caravelles, Kombi's and the Motor Caravans based on them (including Westfalia's) are "whole vehicle" approved under the same groups, although Westfalia's would have undergone additional tests, as is per Autosleeper conversions. Thus, changing the registration details to a "goods vehicle" would not be appropriate for a passenger carrying vehicle.

However, changing a goods vehicle to a passenger vehicle is commonplace - even installing windows in a panel van could be construde as a change of use - before car purchase tax was abolished such a modification had to be declared to Customs and Excise, who placed their levy on the change at market value. Thankfully that practice has stopped. In such cases DVLA are bound to change the vehicle type from goods vehicle to passenger vehicle but they are increasingly asking for photographic evidence, presumably to check that they are not party to systematic "tax avoidance", which must becoming an issue given all of our efforts to avoid paying the new car tax hikes and the LEZ.

The conditions applied to reregistering vans as Motor Caravans also apply to insurance and the MOT. In these cases DVLA use the Type Approval codes already in place as points of reference.

Individual Component Certification

An example of this would be the German TUV pull test - the pull test for a two seater Reimo Variotech is six tonnes; for the three seater ones it is ten tonnes, reflecting the momentum generated by the increased mass of a moving object (in this case each passenger and possibly the seat itself). On passing this test any company, or individual, installing Reimo seats (and any other Reimo kit, for that matter) would not have to submit their conversion for type approval, because the test has already been done.

A typical seat pull test. To gain full vehicle Type Approval a crash test is carried out on a completed vehicle and the results are studied (currently at £50,000 per test, a number of sites around the UK are happy to provide this service, but it does mess with your van, somewhat!!!).

801 Posts
DVLA is required to register a vehicle based on the evidence presented at first registration and is unable by law to change the type approval category once the vehicle has been correctly registered."

However, changing a goods vehicle to a passenger vehicle is commonplace...In such cases DVLA are bound to change the vehicle type from goods vehicle to passenger vehicle...
It would appear that doublespeak is alive and well.

1,257 Posts
Discussion Starter #3
Think about it...

... if you couldn't legitimately reregister your home built camper as a passenger vehicle then strictly speaking you couldn't insure it for carrying passengers, hence DVLA are bound to allow the reregistration of goods vehicles to passenger vehicles, but try proving to DVLA that a vehicle originally designed to carry more than one or two passengers will never carry passengers again, even though you may have taken all the seats out.

After all Caravelles can be considered as Dual Purpose Vehicles like Estate Cars and people carriers that can carry both passengers and goods.

If our campers were uninsurable, our whole scene and the Leisure Vehicle industry, employing thousands of likeminded people, would be decimated overnight. However, the precedent has already been made so they cannot go back on that, and they use the existing framework to refer against (converting a red London Routemaster bus into a motorhome might not be as straight forward, in this day and age)...

With regard to Caravelles being registered as Light Goods Vehicles, that can only be because when they were registered as such at the time of the original sale. They were either incorrectly registered either by mistake, or for dealerships (or certain individuals in those dealerships) to squew their sales figures in order to hit targets and bonuses...

... this is my synical view, and it cannot be proved - however, when MOT computerisation first took off, the DVLA database was littered with petrol cars being registered as diesels, and so on - to get 30 million correct vehicle matches used to be a pain... staking process, but now, after 2 / 3 years, most of these bugs have been ironed out.

Very recently, I advised a client that his two wheel drive, manual Passat was registered as a 4 Motion with Tiptronic transmission. How would that have effected his insurance - indeed in the event of an accident, how could he have proved that it was his vehicle and not a ringer (he had owned it from new, though)?

I would say that no MOT Tester is expert in every make and model built over the last 110 years! Most people, would view any Transporter / Microbus or Transporter / Caravelle as one and the same, especially with the older models, so I would be inclined to defend any official's ignorance between the model types (not helped by staff turnover at VW HQ, I might add)

The extent of our plight, and that of Vito / V-Class, Transit / Tourneo owners, is unique to this vehicle type - that is why I have posted all this stuff here in the Community Forum for easy access to all, and to back up round three of my Governmental and Mayoral lobbying...

2 Posts
Hi there,
I'm a new member so forgive me if I get anything wrong. I could use some help.

I bought a VW T5 in the UK, had a lovely conversion done by a company in Bromley and exported the vehicle to be part of our new life in NZ. Problem is the vehicle needs a low volume certificate. I've had the inspection done and the guy who did it is asking for documentary evidence of the crash worthiness of the Reimo Variotech 2/3 seat bed and also the Reimo seat swivels I had fitted up front.

I am getting precisely nowhere with this, even from Reimo and I could use any help from any members who might know where I can find out any results of pull tests, or which TUV in Germany conducted such tests.

Yours hopefully,
Andy Fennell

P.S. The co that did the conversion are no longer contactable so I suspect voluntarily or otherwise, they are no more!!
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