New emissions for kit cars consultation
Discussion
YOU MUST READ THIS
https://www.gov.uk/government/uploads/system/uploa...
Salient points to start you off
You will note at annex E that no kit car manufacturers, suppliers or kit car clubs have been included as of now
Kit car emissions
Taken from www.gov
Road Cars
Improving air quality and safety
Kit cars
4.10 Kit cars and reconstructed classic cars undergoing IVA will not be required to meet WLTP, given that at present they are not required to meet NEDC or the latest EU standards. Instead they are tested to age-appropriate MOT standards, on the basis of the date of manufacture or first use of the engine.
4.11 We are proposing that for kit cars, compliance with the MOT emissions standards current at the date of registration will be required, despite the use of an older engine. In other words the current relaxation for emissions according to the age of the engine will no longer apply.
4.12 Reconstructed (restored) classic cars undergoing IVA will not be required to meet the latest MOT standards, as long as the appearance of the vehicle is broadly unchanged and the engine is of the same capacity as that supplied with the vehicle when it was new.
4.13 When new vehicles were first required to be fitted with catalytic converters around 1992 (Euro 1 emissions standard), kit car makers typically used older engines which were not fitted with catalytic converters, hence the justification for age-appropriate testing of emissions based on date of engine manufacture or first use. The majority of the fleet is now vehicles up to 25 years old whose engines are fitted with catalytic converters, providing plenty of choice to the kit car builder.
Question.
Are you content with our proposal to require kit cars to meet the latest MOT standards, removing the current rule where vehicles are tested to MOT standards according to the age of their engine?
The consultation period begins on Friday 2 February 2018 and runs until Friday 2 March 2018. Please ensure that your response reaches us before the closing date. If you would like further copies of this consultation document, it can be found at https://www.gov.uk/dft#consultations or you can contact us using the details below if you need alternative formats (Braille, audio CD, etc.).
Please send consultation responses to: Robert Lloyd-Smith
Zone 1/33, Great Minster House
33 Horseferry Road
LONDON SW1P 4DR
Email to: ivs.consult@dft.gsi.gov.uk
When responding, please state whether you are responding as an individual or representing the views of an organisation. If responding on behalf of a larger organisation, please make it clear who the organisation represents and, where applicable, how the views of members were assembled.
A list of the main representative bodies consulted is attached at Annex E. If you have any suggestions of others who may wish to be involved in this process please contact us.
Annex E: List of those notified of the consultation
Society of Motor Manufacturers and Traders (SMMT) National Motor Dealers Association (NMDA)
Vehicle Bodybuilders and Repairers Association (VBRA) National Caravan Council (NCC)
Wheelchair Accessible Vehicle Converters Association (WAVCA) British Independent Motor Traders Association (BIMTA) American Import Agents Association (AIAA)
Niche Vehicle Network (NVN)
National Trailer Towing Association (NTTA)
Recovery Equipment Manufacturers and Suppliers Association (REMSA) Road Safety Markings Association (RSMA)
Freight Transport Association (FTA)
Road Haulage Association (RHA)
Confederation of Passenger Transport (CPT)
Transport for London (TfL)
Local Government Association (LGA)
Low Carbon Vehicle Partnership (LowCVP)
https://www.gov.uk/government/uploads/system/uploa...
Salient points to start you off
You will note at annex E that no kit car manufacturers, suppliers or kit car clubs have been included as of now
Kit car emissions
Taken from www.gov
Road Cars
Improving air quality and safety
Kit cars
4.10 Kit cars and reconstructed classic cars undergoing IVA will not be required to meet WLTP, given that at present they are not required to meet NEDC or the latest EU standards. Instead they are tested to age-appropriate MOT standards, on the basis of the date of manufacture or first use of the engine.
4.11 We are proposing that for kit cars, compliance with the MOT emissions standards current at the date of registration will be required, despite the use of an older engine. In other words the current relaxation for emissions according to the age of the engine will no longer apply.
4.12 Reconstructed (restored) classic cars undergoing IVA will not be required to meet the latest MOT standards, as long as the appearance of the vehicle is broadly unchanged and the engine is of the same capacity as that supplied with the vehicle when it was new.
4.13 When new vehicles were first required to be fitted with catalytic converters around 1992 (Euro 1 emissions standard), kit car makers typically used older engines which were not fitted with catalytic converters, hence the justification for age-appropriate testing of emissions based on date of engine manufacture or first use. The majority of the fleet is now vehicles up to 25 years old whose engines are fitted with catalytic converters, providing plenty of choice to the kit car builder.
Question.
Are you content with our proposal to require kit cars to meet the latest MOT standards, removing the current rule where vehicles are tested to MOT standards according to the age of their engine?
The consultation period begins on Friday 2 February 2018 and runs until Friday 2 March 2018. Please ensure that your response reaches us before the closing date. If you would like further copies of this consultation document, it can be found at https://www.gov.uk/dft#consultations or you can contact us using the details below if you need alternative formats (Braille, audio CD, etc.).
Please send consultation responses to: Robert Lloyd-Smith
Zone 1/33, Great Minster House
33 Horseferry Road
LONDON SW1P 4DR
Email to: ivs.consult@dft.gsi.gov.uk
When responding, please state whether you are responding as an individual or representing the views of an organisation. If responding on behalf of a larger organisation, please make it clear who the organisation represents and, where applicable, how the views of members were assembled.
A list of the main representative bodies consulted is attached at Annex E. If you have any suggestions of others who may wish to be involved in this process please contact us.
Annex E: List of those notified of the consultation
Society of Motor Manufacturers and Traders (SMMT) National Motor Dealers Association (NMDA)
Vehicle Bodybuilders and Repairers Association (VBRA) National Caravan Council (NCC)
Wheelchair Accessible Vehicle Converters Association (WAVCA) British Independent Motor Traders Association (BIMTA) American Import Agents Association (AIAA)
Niche Vehicle Network (NVN)
National Trailer Towing Association (NTTA)
Recovery Equipment Manufacturers and Suppliers Association (REMSA) Road Safety Markings Association (RSMA)
Freight Transport Association (FTA)
Road Haulage Association (RHA)
Confederation of Passenger Transport (CPT)
Transport for London (TfL)
Local Government Association (LGA)
Low Carbon Vehicle Partnership (LowCVP)
t isn’t it 
PaulKemp said:
You will note at annex E that no kit car manufacturers, suppliers or kit car clubs have been included as of now
The established kit car industry looks to be very will represented amongst the bodies listed in Annex E, although I don't disagree that it's still worth making out own representations.A quick check shows Caterham as members of the SMMT and the Niche Vehicle Network list both GBS and Westfield as member companies.
4.11 We are proposing that for kit cars, compliance with the MOT emissions standards current at the date of registration will be required, despite the use of an older engine. In other words the current relaxation for emissions according to the age of the engine will no longer apply.
this is already valid since ever in other EU Memberstates...the reg.date gives the emissiion classification to be fullfilled.
this is already valid since ever in other EU Memberstates...the reg.date gives the emissiion classification to be fullfilled.
not a good idea IMO.
Sure true most new builds will have a post 92/96 engine these days however emmissions tests have got stricter and stricter over the years. Early cat equiped engines are unlikely to be able to pass current emissions even with decent tuning. So it will force people to use much newer engines.
The size of the kit car industry is so small that the environmental arguement for removing the engine age emissions simply isn't there as the emmissions from kit cars are negligible compared to general car usage and other fossil fuel emissions.
Sure true most new builds will have a post 92/96 engine these days however emmissions tests have got stricter and stricter over the years. Early cat equiped engines are unlikely to be able to pass current emissions even with decent tuning. So it will force people to use much newer engines.
The size of the kit car industry is so small that the environmental arguement for removing the engine age emissions simply isn't there as the emmissions from kit cars are negligible compared to general car usage and other fossil fuel emissions.
smokey mow said:
PaulKemp said:
You will note at annex E that no kit car manufacturers, suppliers or kit car clubs have been included as of now
The established kit car industry looks to be very will represented amongst the bodies listed in Annex E, although I don't disagree that it's still worth making out own representations.A quick check shows Caterham as members of the SMMT and the Niche Vehicle Network list both GBS and Westfield as member companies.
I did not see these manufacturers in annex E
Do me a favour and add the link
Ta
Addendum to last post
Caterham are not kit manufacturers as we know them, although you can buy a very expensive box of bits
Westfield would like to be a mini Caterham
I have more respect for GBS as a kit supplier
BUT what about the other respected suppliers and the little guys?
Don’t forget Jeremy Phillips cars are mostly owned and produced by very small companies and what about the true build it from scratch guys.
We have a lot to loose
An awful lot
Caterham are not kit manufacturers as we know them, although you can buy a very expensive box of bits
Westfield would like to be a mini Caterham
I have more respect for GBS as a kit supplier
BUT what about the other respected suppliers and the little guys?
Don’t forget Jeremy Phillips cars are mostly owned and produced by very small companies and what about the true build it from scratch guys.
We have a lot to loose
An awful lot
PaulKemp said:
This is the exact reason I posted
I did not see these manufacturers in annex E
Do me a favour and add the link
Ta
https://www.nichevehiclenetwork.co.uk/about-us/I did not see these manufacturers in annex E
Do me a favour and add the link
Ta
https://www.smmt.co.uk/members/c/
Couple of points need to be clarified I think. My Minari was built using sufficient components from a single donor to qualify for an age related plate. Date of first registration on my V5 is stated as 1st August 1987.
I'm sure others on here have posted that their age related plate V5s state the date of first registration of the kit, rather than that of the donor. It is not clear to me from the text where single donor kits will fall within this legislation. (I understand that my own car should be ok for the moment!)
The second point is more of a technical one for people on here. The implication of clause 4.13 (the way I read it anyway) is that if you use an engine suitable for use with a catalytic converter, you should be able to meet the current MOT requirements.
Is this correct? Is it feasible to make a mid 90s engine meet the current MOT emissions test? Intuitively, it seems unlikely, otherwise the manufacturers would have done it themselves, no?
So, if I were to want to build a Westfield based on an MX5 (or any other MX5 based car for that matter) where would I stand, I wonder?
I'm sure others on here have posted that their age related plate V5s state the date of first registration of the kit, rather than that of the donor. It is not clear to me from the text where single donor kits will fall within this legislation. (I understand that my own car should be ok for the moment!)
The second point is more of a technical one for people on here. The implication of clause 4.13 (the way I read it anyway) is that if you use an engine suitable for use with a catalytic converter, you should be able to meet the current MOT requirements.
Is this correct? Is it feasible to make a mid 90s engine meet the current MOT emissions test? Intuitively, it seems unlikely, otherwise the manufacturers would have done it themselves, no?
So, if I were to want to build a Westfield based on an MX5 (or any other MX5 based car for that matter) where would I stand, I wonder?
Well that's pretty crap.
I'm sure I'm not alone in having a build that due to family and other reasons has already taken many years and will take at least a few more... I know of people who have taken 10 or even 20 years to complete a build.
I have a 1991 engine sat ready and ignoring the cost of the engine itself I have a few k in parts that are specific to that engine and wouldn't transfer to a later one. So while I could get a newer engine it would cost me thousands. Or try and get a 1991 engine to pass current tests. Now I'm sure it *could* be done but I doubt it would be easy or cheap.
I'm sure I'm not alone in having a build that due to family and other reasons has already taken many years and will take at least a few more... I know of people who have taken 10 or even 20 years to complete a build.
I have a 1991 engine sat ready and ignoring the cost of the engine itself I have a few k in parts that are specific to that engine and wouldn't transfer to a later one. So while I could get a newer engine it would cost me thousands. Or try and get a 1991 engine to pass current tests. Now I'm sure it *could* be done but I doubt it would be easy or cheap.
It appears fairly clear.
When you complete IVA, that counts as date of registration. Your build has to comply with MOT rules in place on that day.
A build based on MX5 etc., as long as it has a Cat etc. 'should' pass. A build based on a carb'd Pinto won't.
This proposal is a sledgehammer crack a non-existent nut, given the number of kits on the road and the mileage that they drive...
When you complete IVA, that counts as date of registration. Your build has to comply with MOT rules in place on that day.
A build based on MX5 etc., as long as it has a Cat etc. 'should' pass. A build based on a carb'd Pinto won't.
This proposal is a sledgehammer crack a non-existent nut, given the number of kits on the road and the mileage that they drive...
Please guys, let's try and fight this.
Please respond to the consultation and keep the kit car industry alive a bit longer, not let it go the way of Germany where it's nearly impossible to get a car registered.
Appears this may be applied retroactively. IVA'd your car with an older engine last year? It may need to meet 2017 emissions at the next MOT? Fancy trying to get that old seven with a pinto to meet the emissions regs for when you first registered it? Not going to happen. Most of the kit cars on the road will be untestable if this is made retroactive. And current builders face a serious mountain of effort and cost to comply.
Please respond, and share this info on other forums, and with your kit manufacturer. We need to stress how this will kill the hobby. They consulted on extending the MOT to four years for the first test, the public responded and the idea was cancelled. Lets appeal to sense on this one too.
Please respond to the consultation and keep the kit car industry alive a bit longer, not let it go the way of Germany where it's nearly impossible to get a car registered.
Appears this may be applied retroactively. IVA'd your car with an older engine last year? It may need to meet 2017 emissions at the next MOT? Fancy trying to get that old seven with a pinto to meet the emissions regs for when you first registered it? Not going to happen. Most of the kit cars on the road will be untestable if this is made retroactive. And current builders face a serious mountain of effort and cost to comply.
Please respond, and share this info on other forums, and with your kit manufacturer. We need to stress how this will kill the hobby. They consulted on extending the MOT to four years for the first test, the public responded and the idea was cancelled. Lets appeal to sense on this one too.
Stable door... horse bolted in 1998, when SVA was introduced.
I said at the time (in the magazines, it being before widespread adoption of the internet) that SVA was the thin end of a wedge that would allow ever-tightening regulation to strangle the industry without anything so blatant as an outright ban. 'Oh no, it'll be good for the industry to have standards that people can trust' was the typical response.
Anyone who thinks that the EU will be willing to make a deal on an exception for the UK on such a niche issue, against the background of Brexit and the fact that we've just agreed to toe the line on EU legislation for the transitional period, is delusional.
Even the manufacturers won't have much interest in supporting you; they're just as happy making bigger profits from selling complete kits, including engine and ECU - I'm a member of the Niche Vehicle Network, who are on the consultee list, and they haven't even bothered to contact me about it.
I said at the time (in the magazines, it being before widespread adoption of the internet) that SVA was the thin end of a wedge that would allow ever-tightening regulation to strangle the industry without anything so blatant as an outright ban. 'Oh no, it'll be good for the industry to have standards that people can trust' was the typical response.
Anyone who thinks that the EU will be willing to make a deal on an exception for the UK on such a niche issue, against the background of Brexit and the fact that we've just agreed to toe the line on EU legislation for the transitional period, is delusional.
Even the manufacturers won't have much interest in supporting you; they're just as happy making bigger profits from selling complete kits, including engine and ECU - I'm a member of the Niche Vehicle Network, who are on the consultee list, and they haven't even bothered to contact me about it.
Mistrale said:
It appears fairly clear.
When you complete IVA, that counts as date of registration. Your build has to comply with MOT rules in place on that day.
A build based on MX5 etc., as long as it has a Cat etc. 'should' pass. A build based on a carb'd Pinto won't.
This proposal is a sledgehammer crack a non-existent nut, given the number of kits on the road and the mileage that they drive...
With respect I don't think it is clear. I agree that the idea is to prevent people building kits and using older engines just to avoid needing a Cat and allow them to keep their carbs. (Does anybody do that any more?)When you complete IVA, that counts as date of registration. Your build has to comply with MOT rules in place on that day.
A build based on MX5 etc., as long as it has a Cat etc. 'should' pass. A build based on a carb'd Pinto won't.
This proposal is a sledgehammer crack a non-existent nut, given the number of kits on the road and the mileage that they drive...
What about a single donor kit, though? If I were insane enough to buy that Ginetta G26 that's been on eBay and happened to find a 20k mile Cortina with rapidly decomposing bodywork, I could build the G26 and apply for an age related plate. My direct experience of this is that the date of first registration stated on the V5 is the same as the donor and is unrelated to the date of IVA.
Intuitively, I would suggest that the few cars left of this ilk would fit better into the description included in 4.12 (reconstructed classic) rather than 4.11, other than the bit about the appearance being broadly unchanged.
Frankthered said:
With respect I don't think it is clear. I agree that the idea is to prevent people building kits and using older engines just to avoid needing a Cat and allow them to keep their carbs. (Does anybody do that any more?)
Builders of GT40 replicas for one do. Really needs clarification regarding if they are going to apply this retrospectively. For example my car was IVA'd 1971 engine block quad IDA Webers last year, visual smoke inspection for emissions only. If they now say it will have to meet 2017 MOT emissions checks, (which they appear to be doing) I am stuffed without very expensive modifications prior to it's first MOT.
Please fill in the survey, write to them or both.
Regards
Nick
Edited by Nick Brough on Tuesday 6th February 00:33
IF this come in...my understanding is...
When a car goes in for IVA etc., this date becomes the date of registration. At present, as I understand, the V5 currenty contains a note stating the emissions test required which related to the date of first registration/engine age in the case of the 20 year old Ginetta.
The change is simply that this has now been removed and date of IVA becomes the date of registration regardless of engine age. At this point you will have to meet the MOT emissions (not production limits) in force at that time. These will remain the limits for this car for life (or the next piece of tree hugging appeasement by HMG of the day)
The changes only apply to cars being IVA’d so the Cobra you built last week with a V8 and quad Holleys is ok (for now, see tree hugging note above).
We should still all fill in the feedback and fight this! So few kit cars relatively speaking and so few miles travelled mean the effect on the environment will be zero!
When a car goes in for IVA etc., this date becomes the date of registration. At present, as I understand, the V5 currenty contains a note stating the emissions test required which related to the date of first registration/engine age in the case of the 20 year old Ginetta.
The change is simply that this has now been removed and date of IVA becomes the date of registration regardless of engine age. At this point you will have to meet the MOT emissions (not production limits) in force at that time. These will remain the limits for this car for life (or the next piece of tree hugging appeasement by HMG of the day)
The changes only apply to cars being IVA’d so the Cobra you built last week with a V8 and quad Holleys is ok (for now, see tree hugging note above).
We should still all fill in the feedback and fight this! So few kit cars relatively speaking and so few miles travelled mean the effect on the environment will be zero!
Thanks to the OP interesting if alarming, read. I suggest all kit car / classic car restorers take note:
I replied (to proposed 'dieselgate' and 'kit car' legislation)
With regard to the issue of Dieselgate (Section 2.) Proposed new offence of supplying new vehicles fitted with a defeat device
Questions
1 Do you agree with our proposal to make supply of a vehicle fitted with a defeat device an offence? I do not believe that the offence be limited to future offences as is implied. Although the offence may have been committed at the time of testing, the damage to the environment is ongoing. Therefore the penalty should be ongoing.
2 Do you agree that the offence should be such that manufacturer, importer or dealer could be found guilty of this? Yes, obviously penalties should not be imposed upon the owners who bought the cars in good faith - but upon the manufacturer/importer/dealer in question.
I believe that, as stated, the UK has existing powers to 'punish' VW (and others). What has been lacking is any action. I suggest the State assumes a 20 year life cycle of each vehicle sold with a defeat device and 'fines' manufacturers the highest possible annual charge of VED for each one of these years, and this to be in addition to any VED actually paid by the owner.
e.g. A 'dieselgate' car sold in (say) 2015 would be charged an additional band M. VED of £505 for 2015-16 and £515 for 2016-17 and whatever band M is for the next 18 years. (In addition to any past years, the penalty should apply to the future life of the car).
(source for example above https://www.honestjohn.co.uk/road-tax/budget-2016-... )
Such a seemingly draconian penalty might encourage the manufacturers to buy back the cars thereby taking them off the road at no cost to the State or owners.
There would be legal arguments made by VW (and others) but I think it could be proven in a court of law that because 'dieselgate' gate cars were tested with a 'defeat' device they should automatically be branded as the most polluting simply because they were not sold a seen. ie the buyer genuinely believed they were purchasing a vehicle that was 'cleaner' than that actually supplied (when used in the real world as opposed to when being tested in laboratory conditions).
We have had many examples of immoral business practices in the financial services industry (Endowment misselling, LIBOR etc) and it would now seem that this cancer has spread to the auto industry. The Government must draw a line in the sand and take action NOW.
The second point I would like to make concerns Proposed changes to emissions standards for new vehicles using national schemes, specifically the proposed legislation with regard to kit cars and reconstructed (restored) classic cars (paras 4.10 - 4.13) .
Question 10
Are you content with our proposal to require kit cars to meet the latest MOT standards, removing the current rule where vehicles are tested to MOT standards according to the age of their engine?
I strongly oppose this proposal: The number of kit cars / restored classic cars that are built each year is, in in terms of environmental damage, insignificant because of the small numbers built rebuilt, their limited mileage and the fact that they tend to be used in the country and not for commuting in crowded and polluted city streets.
The kit car / classic car industry is not just a hobby for many but provides employment for 1000's. In the post Brexit world the UK's micro industries must be encouraged and not legislated out of existence.
It was, of course, the State (as a result of lobbying by VW & others) that encouraged the sale of 'dieselgate' cars that have caused the present pollution issues.
I am reminded of a quote from Ronald Reagan The nine most terrifying words in the English language are, "I'm from the government and I'm here to help"
I replied (to proposed 'dieselgate' and 'kit car' legislation)
With regard to the issue of Dieselgate (Section 2.) Proposed new offence of supplying new vehicles fitted with a defeat device
Questions
1 Do you agree with our proposal to make supply of a vehicle fitted with a defeat device an offence? I do not believe that the offence be limited to future offences as is implied. Although the offence may have been committed at the time of testing, the damage to the environment is ongoing. Therefore the penalty should be ongoing.
2 Do you agree that the offence should be such that manufacturer, importer or dealer could be found guilty of this? Yes, obviously penalties should not be imposed upon the owners who bought the cars in good faith - but upon the manufacturer/importer/dealer in question.
I believe that, as stated, the UK has existing powers to 'punish' VW (and others). What has been lacking is any action. I suggest the State assumes a 20 year life cycle of each vehicle sold with a defeat device and 'fines' manufacturers the highest possible annual charge of VED for each one of these years, and this to be in addition to any VED actually paid by the owner.
e.g. A 'dieselgate' car sold in (say) 2015 would be charged an additional band M. VED of £505 for 2015-16 and £515 for 2016-17 and whatever band M is for the next 18 years. (In addition to any past years, the penalty should apply to the future life of the car).
(source for example above https://www.honestjohn.co.uk/road-tax/budget-2016-... )
Such a seemingly draconian penalty might encourage the manufacturers to buy back the cars thereby taking them off the road at no cost to the State or owners.
There would be legal arguments made by VW (and others) but I think it could be proven in a court of law that because 'dieselgate' gate cars were tested with a 'defeat' device they should automatically be branded as the most polluting simply because they were not sold a seen. ie the buyer genuinely believed they were purchasing a vehicle that was 'cleaner' than that actually supplied (when used in the real world as opposed to when being tested in laboratory conditions).
We have had many examples of immoral business practices in the financial services industry (Endowment misselling, LIBOR etc) and it would now seem that this cancer has spread to the auto industry. The Government must draw a line in the sand and take action NOW.
The second point I would like to make concerns Proposed changes to emissions standards for new vehicles using national schemes, specifically the proposed legislation with regard to kit cars and reconstructed (restored) classic cars (paras 4.10 - 4.13) .
Question 10
Are you content with our proposal to require kit cars to meet the latest MOT standards, removing the current rule where vehicles are tested to MOT standards according to the age of their engine?
I strongly oppose this proposal: The number of kit cars / restored classic cars that are built each year is, in in terms of environmental damage, insignificant because of the small numbers built rebuilt, their limited mileage and the fact that they tend to be used in the country and not for commuting in crowded and polluted city streets.
The kit car / classic car industry is not just a hobby for many but provides employment for 1000's. In the post Brexit world the UK's micro industries must be encouraged and not legislated out of existence.
It was, of course, the State (as a result of lobbying by VW & others) that encouraged the sale of 'dieselgate' cars that have caused the present pollution issues.
I am reminded of a quote from Ronald Reagan The nine most terrifying words in the English language are, "I'm from the government and I'm here to help"
Edited by alfaspecial on Tuesday 6th February 14:20
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