When the European Parliament Historic Vehicle Group (EPHVG) met in May, Szabolcs Schmidt the head of the EC Road Safety Unit, mentioned that proposals for revisions to the Roadworthiness Testing Directive, following a 2010 consultation, were expected ‘in the summer’. In July, the European Commission published the detail which turned out to be a proposal to replace the current Roadworthiness Testing Directive (2009/40/EC) with a completely new Directive.
The draft of the new Directive has implications for all motorists, not just historic vehicle owners. Amongst other things, the draft includes requirements to test all trailers (which in turn implies a registration system) and requires tests to make reference to a vehicle’s original ‘technical characteristics’. The meaning of this expression is not defined. National governments are granted the right to make their own testing arrangements for ‘vehicles of historic interest’. A vehicle of historic interest is then defined as one that
· Was manufactured more than 30 years ago
· Is maintained by use of replacement parts which reproduce the historic components of the vehicle
· Has not sustained any change in the technical characteristics of its main components such as engine, brakes, steering or suspension; and
· Has not been changed in its appearance.
The FBHVC considers this definition to be unworkable and completely unacceptable. FBHVC also rejects the suggestion that Roadworthiness Testing should relate to a vehicle’s ‘technical characteristics’, whatever the age of the vehicle. Modifications, alterations and improvements are all part of the history of motor vehicles and the older the vehicle, the more likely it is that it will have been altered at some stage. At present the basic tenet of a UK MoT test is that it is one of mechanical fitness. There is no database of original specifications for UK vehicles, so testing to original ‘technical characteristics’ is simply pie-in-the-sky.
Earlier this month, the Department for Transport asked stakeholders for comment on the proposals. FBHVC will be responding formally to this request when further analysis of the detailed proposals has been completed. FBHVC will be discussing the implications of the proposal with the international organisation, FIVA, and through them with the EPHVG group as well as with the All Party Parliamentary Historic Vehicle Group in the UK.
It should be remembered that this is still just a proposal. It has to have approval by each EU member country before it is adopted. Some media commentary on this topic has tended towards the ‘we’re doomed’ end of the scale. It is certainly a serious issue and FBHVC is treating it accordingly.
Amendment to the EC Roadworthiness Package for Historic Vehicles (Responsible department: Department for Transport): The European Commission is proposing to outlaw the use of any modifications and non-original components to historic vehicles by introducing the following legislation; Periodic roadworthiness tests for motor vehicles and their trailers and repealing Directive 2009/40/EC". Many elements of this legislation make good sense, however the legislation in its current format would immediately render thousands of historic vehicles illegal because of ‘common sense enhancements’. This would jeopardise jobs in this valuable industry and the multi million pound supply chain, and in many cases actually rendering safety enhancements illegal as they were not fitted by vehicles designers. The request is that Parliament consider the implications of banning modifications to historic vehicles, and suggest that the EU policy should be changed to closer reflect the sensible use of modifications in keeping with the vehicles historic design and nature? If you're concerned about the proposed EC changes to the regs about modified vehicles, you might want to sign this petition at http://epetitions.direct.gov.uk/petitions/37784