We recently contacted the team responsible for administering the forthcoming EC Whole Vehicle Type Approval (ECWVTA) Scheme (see News June 18th 2008) - and raised several questions with them.

We have now received their replies;

Q. Are there any plans to "licence" RV Dealers, allowing them to fast-track vehicle registrations thru the ECWVTA process and requiring that all registrations (including private imports) are administered thru such a "licensed" dealer, who could possibly levy large fees for this ?

A. I can reassure you that there is no possibility of RV Dealers being "licensed" by the DfT for ECWVTA purposes and (therefore) charging huge fees. ECWVTA and bIVA are available to anyone who can demonstrate the vehicle meets the standards. Only the government (Vehicle Certification Agency or VOSA) can issue approval.

Q. The RVOA consider it important that any changes in legislation offer a level playing field for dealers and individuals alike; not favouring one or the other. Can you confirm that private importers will be able to submit a vehicle for bIVA testing and registration in the same manner as RV dealers etc.

A. There is (and will be) a level playing field for everyone - although given the importance of vehicles to road safety and the environment and their highly technical nature, it is only natural that some technical knowledge will be necessary for those looking to sell or import vehicles.

Q. Has any consideration been given on how best to explain the requirements of bIVA testing in layman's terms, allowing a private importer the opportunity to digest the information BEFORE importing a vehicle?

A. The VOSA bIVA (and IVA) inspection manuals are now on the internet to download (HERE). These set out the requirements in ways that are easier to understand than the formal Regulations which we are consulting upon.

Q. There are concerns with regard the proposed costs in obtaining the relevant approvals and I would be grateful to know which parts of the Fee Proposals from the Consultation Document are relevant to the registration of a motorhome from North America. The fees stated seem excessive and I'm not sure which are actually relevant for bIVA testing.

A. The cost for testing a motorhome via bIVA would be £280. See paragraphs 115-116 on page 30 and Table 9 of the Consultation document.

Q. There was at one time, a list of "approved and illegal motorhomes" compiled by the Society of Motor Manufacturers and Traders (SMMT). This list provided a black and white account of which vehicles could be imported without further inspection. Could the List not have been retained and any flaws rectified, rather than scrapping it and leaving people in the dark?

A. The "List" fell into disrepute due to it being impossible to describe the precise specification of the vehicles concerned - for example, some vehicles of a particular model might be fitted with an accessory (eg a ladder) at the back and others not. Therefore some are too long and some are not. Without a detailed specification it is impossible to know if the vehicle is in line with previously submitted vehicles of the same make and model.

Q. The Consultation Process states that any submissions made are available for public view via the Freedom of Information Act. Therefore, under the Act, can you please provide details of the submissions made by the RVDA, SMMT and NCC.

A. I have not received any written proposals from SMMT, NCC or RVDA (or any other party) regarding testing or registration of motorhomes.

Q. Most motorhomes from North America carry a label confirming the vehicle meets the construction requirements of the RV Industry Association. Could this be accepted for some or all of the bIVA test ?

A. We are not considering accepting motorhomes bearing an RVIA badge as meeting various aspects of bIVA. However, we are investigating whether the United States office of VCA would be able to carry out bIVA inspections or pre-inspections in the USA, or at least offer advice, in order to prevent someone bringing a vehicle back to the UK and then having it refused.

Q. Regrettably, the RVOA do not have the funds of combined businesses
(like the RVDA) and are unable to finance detailed research into the various technical requirements of the proposals. Can you offer any assistance to guide us through the actual testing procedure? This would allow the RVOA to gain a better understanding on how things might work for private importers and whether the proposals would place unfair restrictions on them.

A. Motorhomes will not be subject to (compulsory) bIVA until April 2012, and we hope to run a pilot testing exercise before then to assist applicants. In light of that it may be possible to make changes to the scheme or the inspection manuals. Sometime in the middle to end of 2009 I envisage a pilot exercise on motorhomes with interested parties such as NCC, RVDA and yourselves (the RVOA) submitting vehicles for a pilot bIVA where VOSA would go through the test and demonstrate the areas being examined.

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The RVOA are extremely pleased with the replies above. We will continue to raise questions on how ECWVTA (and other items of legislation) affect RV owners in the UK.

If you have any questions or concerns, please get in touch with us and we'll ask them on your behalf.

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* the ECWVTA Scheme is voluntary from '09 and compulsory from '12.