Car modifications - becoming illegal?

[sorcerer]

Just found some info on a usenet newsgroup that may be of interest to us LPG users, or it may apply only to 'historic' vehicles, I'm not sure - but worth a look anyway

More info here: http://www.the-ace.org.uk/armageddon/

[Gilbertd]

From a simple read through it appears that it's a case of putting 2 and 2 together and making 76. It doesn't ban modifications, it bans any modification that would result in that vehicle failing the type approval test that it passed when it was new (assuming it is new enough to have been submitted for Type Approval in the first place). So, if you take the 1 litre engine out of your Nissan Micra and substitute an 6 litre V8, as long as the emissions are in limits for that type of engine, then it's fine. If however, you stick sharp edged badges or fibreglass tat that has exposed edges that have a radius of less than 2.5mm, it will fail. Hopefully it may affect some of the abysmal 'modified' vehicles of the www.barryboys.co.uk ilk. They have also confused Vehicles of Historic Interest with Historic vehicles. A Historic vehicle is one that was first registered prior to 1973 so qualifies for free road tax and can be modified in any way you like as long as it is still roadworthy. There's a Historic vehicle in my garage at the moment that has just been checked and registered by DVLA, a 1957 Austin Healey fitted with the running gear from a Cobra! (eBay item 320965586769 in case anyone is interested). A vehicle of Historic Interest is just that, a vehicle that is a pre-production prototype, a one-off or a car that has some historic interest, and in order to be of historic interest must remain standard.

[markocosic]

From a simple read through it appears that it's a case of putting 2 and 2 together and making 76.

The ACE like doing that.


Guaranteed It will achieve zero (barryboys aren't law abiding anyway) and annoy many (the rest of us). It's like whacking a 20 mph limit, speedbumps, and a speed camera in a residential area, because once upon a time a kid died when a stolen car mowed them down at Mach 3. Civil service moron sees speeding vehicle as the problem and the speed enforcement as a solution, completely failing to realise that speeding vehicle is a symptom of morons having access to vehicles and that annoying the rest of the world acheives nothing.


Otherwise, I can see it banning any meaningful post-registration modifications to post 1998 vehicles without having to re-register them. Not necessarily the worst thing if you're UK based, like Q-plates and not being able to export to Europe...


AFAIK LPG conversions render type approvals null and void. (not homologated on that fue?l) Certainly any modifications to the monocoque or OE chassis rails/crossmembers do render the registration of the vehicle null and void. Right now today and have done since 1998. Nobody cares to enforce it though, unless you do something else to bring the vehicle to DVLA's attention. (engine number/capacity change on a post 1972 vehicle raises flags and a body style change on a monocoque is an instant go back to Old Kent Road move) They de-register the vehicle due to the invalidated Type Approval (or failure on the 8 points system) and invite you to submit it for an IVA. (new version of the SVA.

If however, you stick sharp edged badges or fibreglass tat that has exposed edges that have a radius of less than 2.5mm, it will fail.

Barryboys are usually perfectly ok provided that their lights are e-marked - colours and stick on tat don't count. It's the genuine enthusiasts, hot-rodders, custom car builders etc that get nailed for the odd bulkhead dent around the twin webers, or shifting the gearbox crossmember 3" for the 5-speed box etc.


The IVA is not a problem in itself, save the £450 and the fact that no standard mass-produced car would pass it without modification. The first thing you'll need to do is remove the airbag system for example.

http://www.speedview.co/wordpress/wp-co ... g_8451.jpg
(my entertainment for VOSA's technical department)

A Historic vehicle is one that was first registered prior to 1973 so qualifies for free road tax and can be modified in any way you like as long as it is still roadworthy.

Except that you can't modify the chassis or monocoque in the slightest. Strictly speaking.

[rossko]

AFAIK LPG conversions render type approvals null and void. (not homologated on that fue?l)

No idea meself, but an alternative view is that the conversion is just a stick-on. The original fuel system is unmolested.
Makers like Vauxhall and Volvo do I'm sure submit their LPG models for true type approval.

But I'm not so sure about the likes of Mitsubishi, Proton etc ... the vehicles are converted "at the dockside" by the UK subsidiary before sale in UK. I doubt these locally created LPG models go for the full type approval, I wonder what their view is. It must be the same as when an importer fits say different wheels for the local market, how does that go?

[Gilbertd]

The Type Approval only applies to a new vehicle, once it is registered it is no longer new so modifications can be made. We've run into this at work. We have a VW Transporter van which has additional seating in the back and only two seats in the front. The company that converted it simply removed the front passenger twin seat and bolted it to the floor in the back. They then got a drivers seat from a LHD version and fitted that in the front as the single passenger seat. This vehicle is due to be replaced and the conversion company weren't sure if they could do the same on the new one as rear seats must be fitted on runners and not simply bolted in. They checked with VOSA and were told that if the work was done prior to it being registered, it would invalidate the type approval so it would not be possible to register it but what you do once it has been registered doesn't. Otherwise you'd never be able to convert an old ambulance into a camper van for instance. Once registered then it is the Construction and Use regulations that are relevant, not the original type approval.

I would assume that the factory approved LPG conversions were done after a vehicle had been registered.

[markocosic]

If you touch a monocoque (even with a self tapper) or interfere with the OE fuel system in any shape or form (splicing wires) then you render the approval null and void. Technically.

Ditto welding a repair patch onto a vehicle for an MOT. (replacing an entire OE panel with another OE panel affixed the same way as the OE panel was is ok though) Technically.

VOSA take a very pragmatic approach. Numbers match, basic safety concerns (MOT) addressed, all is well as far as they are concerned. Bigger things* to worry about.

DVLA can be good or can be a pain in the backside, depending on who you get to deal with. Local offices are usually ok, and the "central casework group" are usually ok, but anybody Swansea based...

*The VW scene, Drift scene, and stretch limo operators are their current pet hates. The first two do some pretty bloody dumb chassis/suspension/steering mods for lows/deliberately dangerous handling that are starting to show up on accident stats, so VOSA have introduced an "inappropriate modifications" fail for steering/suspension. The latter keep piling 20 drunk fat Doncaster birds into a shonky stretch limo and again this is showing up on the accident stats, hence it being near impossible to register a stretch limo (other than light trucks that can both take the weight and be adapted to the bus regs) in the UK these days.

Importers are shady. Some are homologated (you can be a "manufacturer" if you buy an unregistered vehicle, modify it, then submit for approval). Usually I think they're making fraudulent declarations on the registration forms. "Yes, this vehicle is standard and new," where actually they should be ticking the "No, this vehicle is not standard and needs to be submitted for Individual Vehicle Approval" box. Wheels can be ok if they're approved themselves and a size on which the vehicle was homologated. (aftermarket 15x7s are ok if the car came with 15x7s as a homologated factory option) You need to watch it with insurers though, as their systems show what the car left the factory with. My MX5, like most other UK MX5s, left the factory on 14" steelies. The UK dealer network then had a deal with TSW to make aftermarket rims with Mazda centrcaps, and they switch them all out when new. All ok from an approval point of view, but some insurers want to see these declared as a modification from the factory spec. I only know this as the forums are alive with perfectly well-intentioned people getting shafted by their insurers for failing to declare that the 14" allow with Mazda written on it that was supplied with their Mazda when new by their Mazda dealer was a modification...

Aviva are probably one of the better ones for "standard" modifications. Wheels ok if they were available as a dealer option (even if not supplied with vehicle). Towbar ok. LPG ok. Radio worth less than 250 quid ok. All an online tickbox with no premium change. Good luck with anything not run-of-the-mill though!

VOSA and DVLA, to their credit, have better things to do than whinge about holes in the bodyshell.

[markocosic]

They checked with VOSA and were told that if the work was done prior to it being registered, it would invalidate the type approval so it would not be possible to register it but what you do once it has been registered doesn't.

I suspect what they actually said was more along the lines of:

If the work was done prior to it being registered, it would invalidate the type approval so it would not be possible to register it.

What you do once it has been registered doesn't [automatically de-register it]

What I guarantee that they did not say is:

Modifications after registration do not invalidate the Type Approval.

The Type Approval is absolutely invalidated. All this fuss by ACE is because the EU are proposing revamping the testing regime (MOTs) in order to prevent some countries (primary the UK and club med/east of the iron curtain) from systemically turning a blind eye to it.

Some helpful souls in the civil service who will even drop the relevant hints as to how to avoid getting caught in the paperwork - you probably got one of those on the phone.

As above, there are some things that automatically raise a red flag. Change body style, lower the roof etc, and the DVLA will say that "this is obviously a modified shell, your V5 is invalidated, please go for IVA and re-register." Keep the modifications within limits (holes for LPG, spoilers and sideskirts, camper van kit-out, dint in the bulkhead for the webers, MOT rust patch) and they're not interested in enforcing it. (but the EU want to as the French and Germans have a huge car industry)


Who did the seatbelt mount calcs/tests in the van by the way, or were they factory mount points?

[Gilbertd]

The Type Approval is absolutely invalidated.

It may well be if a testable item is modified but when is Type Approval checked? At registration and never again after. Unless the vehicle is unregistered because it is an import and is over 10 years old. Then all it requires is an MoT certificate......

As above, there are some things that automatically raise a red flag. Change body style, lower the roof etc, and the DVLA will say that "this is obviously a modified shell, your V5 is invalidated, please go for IVA and re-register." Keep the modifications within limits (holes for LPG, spoilers and sideskirts, camper van kit-out, dint in the bulkhead for the webers, MOT rust patch) and they're not interested in enforcing it.

I agree, a change of body style may well require you to IVA a car and re-register it, or at the very least take it to your loacl DVLA office for them to check. If you make major modifications and inform DVLA (as you are legally obliged to do) then they may well want the work checking. Minor mods and repairs of the type that do not require them to be notified but would either not affect items that are tested in the IVA test or would still pass it anyway.

Who did the seatbelt mount calcs/tests in the van by the way, or were they factory mount points?

As VW do a Transporter van with rear seats, the seatbelt mounting points are there in the floor anyway so they were used. My organisation has quite a number of modified vehicles of one sort or another, in fact we have very few unmodified vehicles. They are all leased and the mods done by the same companies that fit out vehicles for the emergency services, military, utility companies, etc.

[markocosic]

The Type Approval is absolutely invalidated.

It may well be if a testable item is modified but when is Type Approval checked? At registration and never again after.

This is what the proposed changes are all bout. Bringing the "has this been modified since it left the factory" into the testing regime. (MOT)

I agree, a change of body style may well require you to IVA a car and re-register it, or at the very least take it to your loacl DVLA office for them to check. If you make major modifications and inform DVLA (as you are legally obliged to do) then they may well want the work checking. Minor mods and repairs of the type that do not require them to be notified but would either not affect items that are tested in the IVA test or would still pass it anyway.

At the moment, the "radically altered vehicle" is the only time that Type Approval validity is checked.
Proposed changes would check it at MOT time too. Even minor mods and repairs invalidate the Type Approval, whether you are required to notify the DVLA or not.

More of a problem than you think - no massed produced vehicle will pass the IVA test without modification. Airbag removal.

Most passenger cars won't pass axle weights the way that VOSA calculate either. (68 kg in each seat, 7 kg luggage in luggage area, 100 kg nose weight on towbar, full of fuel and fluids) Both the MX5 and the Dailer are well over their official "kerb weight" to begin with (manufacturers supply poverty-spec models with ultra thin paint and soundproofing/sheetmetals at minimum tolerances etc for homologation, in order to bump up fuel figures and whatnot) and if you occupy all seating positions and luggage (and towbar noseweight, if fitted) they're over the offical gross vehicle weights. Problem!

As VW do a Transporter van with rear seats, the seatbelt mounting points are there in the floor anyway so they were used.

That's fine. Manufacturer mountings and seats type approved elsewhere are deemed to be acceptable.

Anything else is tested to a higher, IVA, standard. I've yet to see a floor mounted pedestal seat with integral shoulder belts that'll pass the test. (manufacturer's ones won't, but that's fine because they're a manufacturer)

They are all leased and the mods done by the same companies that fit out vehicles for the emergency services, military, utility companies, etc.

Those companies are having to be more and more careful, and will be hit hard if what the EU is "proposing" is implemented.

Beware crown exemption. I tried to up-plate the axle weights on the XJ by using that Jankel armoured XJ8s as an example. VOSA stated that those vehicles were unroadworthty, as they were unable to show them passing durability tests on a shaker rig. (they won't - servicing manual lists all the front suspension bushes and balljoints every 10k and in practice the records show every 5k)

Newer armoured Jaguars are a factory conversion, pre-registration, and homologated separately. The only way to register them legitimately since the IVA came in. Volvo have an S80 heavy-duty platform and take orders for hearses/ambulances directly now. All moving away from legitimate "modification" and into the hands of the manufacturers. Barry boys can stick on what they like though.

[Talkingcars]

I've just scrolled to the bottom of this so escuse me if I repeat anything.

However I have read the whole of the EU white paper and it is nasty - basically what they are trying to do is bring all countries in to line, most of it actually falls below what is legally required in the UK but they have snuck a little line in there to cover type approval - anything that isn't covered in type approval will become illegal and a new MOT will be required.

A new MOT will also be required if you sell the car.

The 30 year no MOT rule will apply to any vehicle over 30 years that is exactly as it was when new.

They also plan to include motorbikes and mopeds which have been included in the UK MOT since before I new what a car was 30 years ago.

The only good thing I see is MOTs for trailers (although these already apply to commercial trailers).

I plan to spend a few days now I am back from holiday to look in more depth and work out a suitable response and who to send it to.