V5 Documentation - DVLA Rule Change for Motor Caravan Reregistration June 2019

[oldiebut goodie]

I'd use their own documentation against them. These documents were only updated in May this year.
V5C log book
It is a legal requirement that all UK registered vehicles are classified correctly on the V5C log book. All campervans, motor caravans and motorhomes fall into the DVLA category of ‘motor caravan’. If you have converted a van into a motor caravan then you must return the V5C to DVLA for body type amendment.

DVLA is required to record the details of vehicles for road safety and law enforcement. The body type information held on the vehicle record must describe what a vehicle actually looks like. This description, in addition to other distinguishing features, enables the police and other enforcement agencies to identify a particular vehicle. Therefore, the body type will not be changed unless the exterior of the vehicle actually appears to be a motor home.

Motor caravan minimum features
In order for a converted vehicle to qualify as a motor caravan it must have certain minimum features:

• a door that provides access to the living accommodation
• a bed, which has a minimum length of 1800mm or 6 feet - this can be converted from seats used for other purposes during the day but must be permanently fixed within the body of the vehicle
• a water storage tank or container on, or in, the vehicle
• a seating and dining area, permanently attached to the vehicle - the table may be detachable but must have some permanent means of attachment to the vehicle. It is not good enough to have a loose table
• a permanently fixed means of storage, a cupboard, locker or wardrobe
• a permanently fixed cooking facility within the vehicle, powered by gas or electricity
• at least one window on the side of the accommodation

If the vehicle has all of these features present, permanently fixed and installed properly, then it is a legal requirement to have it reclassified as a motor caravan on the V5C.

I am sorry but it does appear that people are still conveniently omitting the body type requirement ( Not that it is defined above), this is what is being amended on the V5 not the interior fixtures and fittings. Everyone appears to be reading the internal requirements in isolation whereas the body type requirement needs to be satisfied first. ( I am not in agreement with the way that it is set out but the 1st requirement is clearly stated to be the body type) If you throw this document back at the DVLA they will just point you to the body/exterior change every time.

I spent quite a few years dealing with directions like these as a Civil Servant so it may be easier for me to digest the offending document but it must be plain for all to see that the body type requirement must be satisfied first. ( I am all for the blanket amendment of the V5 with the internal changes defining a motor caravan as it used to be but you cannot argue against what the current requirements are).

 

[j4ckal]

I am sorry but it does appear that people are still conveniently omitting the body type requirement ( Not that it is defined above), this is what is being amended on the V5 not the interior fixtures and fittings. Everyone appears to be reading the internal requirements in isolation whereas the body type requirement needs to be satisfied first. ( I am not in agreement with the way that it is set out but the 1st requirement is clearly stated to be the body type) If you throw this document back at the DVLA they will just point you to the body/exterior change every time.

I spent quite a few years dealing with directions like these as a Civil Servant so it may be easier for me to digest the offending document but it must be plain for all to see that the body type requirement must be satisfied first. ( I am all for the blanket amendment of the V5 with the internal changes defining a motor caravan as it used to be but you cannot argue against what the current requirements are).

I believe the majority do meet the body type requirement though, due to this statement at the beginning;
'All campervans, motor caravans and motorhomes fall into the DVLA category of ‘motor caravan’.

A converted van with full side/rear windows, pop-top, fixed awning, external water fill/hook up and bike rack is a 'campervan' to me.

When you see a California on the road you don't think, oh look at that van with side windows. I'd say 99% of people would think that's a nice looking campervan and to the DVLA a campervan is a 'motor caravan'. Unless I'm reading it wrong of course?

 

[Grim Reaper]

So, I'm thinking of buying these two items Elegant Water Filler Cap - Black, water Fittings, campervan, caravan and motorhome water fittings equipment - Grasshopper Leisure and Mains Inlet, Caravan & Motorhome Electrical, motorhome electrical accessories - Grasshopper Leisure and removing enough of the back side of each to allow me to temporarily stick them both to the side of my van (in an awkwardly prominent place) for the photo shoot as these are generally the only items that could outwardly distinguish a campervan from a plain van. (my water and EHU inlets are actually hidden under the rear light clusters on either side) and see how that plays out.
The fake inlet covers will then be available for posting to any member that needs them to do the same. (assuming it works)

 

[oldiebut goodie]

As I stated earlier in this thread 'All campervans, motor caravans and motorhomes fall into the DVLA category of ‘motor caravan’ is the DVLA's attempt at saying that the various terms " campervans, motorhomes " are called "motor caravan for their purposes" ( although they chop and change in the text!) This has nothing whatsoever to do with the body type requirement.
This is all to do with the "new" requirement of body type change that commenced around 2012 and has been more rigidly enforced since April this year.

If no one, industry/ here/ other forums/petition/etc., appears to be getting anywhere with this intransigence on the part of the DVLA I will attempt to go over the DVLAs head via the old school network to someone who has the ear of the PM but I am loath to presume on an old friendship if it can be dealt with another way especially as he is up to the neck in the quagmire that is Brexit.

 

[DXX]

As I stated earlier in this thread 'All campervans, motor caravans and motorhomes fall into the DVLA category of ‘motor caravan’ is the DVLA's attempt at saying that the various terms " campervans, motorhomes " are called "motor caravan for their purposes" ( although they chop and change in the text!) This has nothing whatsoever to do with the body type requirement.
This is all to do with the "new" requirement of body type change that commenced around 2012 and has been more rigidly enforced since April this year.

If no one, industry/ here/ other forums/petition/etc., appears to be getting anywhere with this intransigence on the part of the DVLA I will attempt to go over the DVLAs head via the old school network to someone who has the ear of the PM but I am loath to presume on an old friendship if it can be dealt with another way especially as he is up to the neck in the quagmire that is Brexit.

While your at it can you get Road Tax and Diesel Duty reduced......just asking

 

[oldiebut goodie]

 

[Neuon2003]

I spent quite a few years dealing with directions like these as a Civil Servant so it may be easier for me to digest the offending document but it must be plain for all to see that the body type requirement must be satisfied first.

With your experience/contacts, can I ask how would you advise on this issue (raised earlier in this thread (Post 169))?

It is a legal requirement that all UK registered vehicles are classified correctly on the V5C log book. All campervans, motor caravans and motorhomes fall into the DVLA category of ‘motor caravan’. If you have converted a van into a motor caravan then you must return the V5C to DVLA for body type amendment

So, the V5C has to be returned to DVLA "if you have converted a van into a motor caravan". That means the duty to submit the V5C arises after conversion into a motor caravan. However, it is not possible to determine the existence of this legal duty because there are no means before the V5C is submitted to establish if you have converted a van into a motor caravan. That is because the Guidance document which establishes the existence of the conversion to a motor caravan is silent on how to determine whether "the exterior of the vehicle actually appears to be a motor home".

 

[Neuon2003]

At the end of the call, I asked for details of the DVLA complaints procedure and was assured that I would get the information in the post but it wouldn't make any difference to their attitude. .

Complain, complain, complain, complain! And then complain some more. Use the official DVLA complaints process to the fullest extent possible, including the various stages and appeals.

DVLA et al hate official complaints, as it means they have to do something. Complaints raised using the complaints procedure are traceable and mean that:

• A Complaints procedure has to be followed.
• DVLA management cannot maintain they knew nothing.
• Rises in complaints can trigger other internal processes and reviews.
• It is likely that numbers of complaints are linked to Departmental and Agency performance targets and staff bonuses.

In May 2019 DVLA retained their Customer Service Excellence (CSE) accreditation for the 10th successive year. You can bet they really do not want to jeopardise this. How can it be that an organisation with such a CSE record cannot/will not provide appropriate advice to its Customers, especially as its Customers are unable to meet their legal obligations without such advice? DVLA Blog: 25 years of Customer Service Excellence: how we do it

 

[Neuon2003]

I sent an email to this address about a fortnight ago asking for confirmation on a diesel hob. No reply as yet. Tried facebook messenger as well but the reply was just the same stuff as the website. Quite disappointed by the lack of human response.

I have also had no response as yet to an email sent to IVS requesting further information on the external appearance criteria for a motor caravan (camper van) to look like a motorhome. According to the DfT reception (tel: 0300 330 3000):

• There is no way to contact IVS other than by email to ivs.enquiries@dft.gov.uk
• If you do not have email access, DfT reception will send an email on your behalf.
• IVS have a performance target to respond to emails by 20 working days.
• If you have had no response by then, contact DfT reception who will send IVS an email requesting a response. This will assume that IVS can confirm receipt of the initial email.
• DfT reception said that IVS has to respond to any internal follow-up email quicker than a further delay of 20 working days.
• DfT reception agreed that could be prudent to mail IVS a copy of any email, to save any email receipt ambiguity.
• DfT reception will not disclose the DfT escalation procedure in the event of any non-answer from IVS.

UK Open Government Network – Making government work better for people through transparency, participation and accountability

 

[oldiebut goodie]

With your experience/contacts, can I ask how would you advise on this issue (raised earlier in this thread (Post 169))?



So, the V5C has to be returned to DVLA "if you have converted a van into a motor caravan". That means the duty to submit the V5C arises after conversion into a motor caravan. However, it is not possible to determine the existence of this legal duty because there are no means before the V5C is submitted to establish if you have converted a van into a motor caravan. That is because the Guidance document which establishes the existence of the conversion to a motor caravan is silent on how to determine whether "the exterior of the vehicle actually appears to be a motor home".

I really don't know as the document seems to have been cobbled together by a tribe of monkeys! I have attempted to wander through various EU directives but have found nothing as yet concerning body type. It is most probably buried in a UK SI somewhere, it is just a case of finding it ( if it exists).

 

[oldiebut goodie]

I have come across this response ( Motor Caravans - Minimum Requirement of a 2 ring cooking facility or microwave - a Freedom of Information request to Department for Transport) from DfT concerning requirement for 2 ring cooker which has an interesting sentence contained within:

"Thank you for your email of 15 April to Department for Transport (DfT) Freedom of
Information Team, which has been passed to the Driver and Vehicle Licensing
Agency (DVLA) to respond.

The guidance you refer to is not prescribed in law but has been established, by the
Department for Transport, to assist motorists when they carry out “do it yourself”
conversions of their motor vehicles into “camper vans”/ “motor homes”.

The importance of the guidance, particularly in relation to incorporating fitments to a
vehicle, is for safety not to be compromised but, there would be no concern if the
cooker comprised of either one or two rings and it has been fitted correctly.

The register maintained by DVLA is based on vehicles and their keepers. The
register is essentially maintained to assist with road safety, revenue collection, and
law enforcement, i.e. the person responsible for their day to day use and licensing on
the public roads. For these reasons therefore, DVLA is concerned that they are being
informed about changes as and when they occur, but in particular when the vehicle’s
body type and/or its outward appearance is changed. "

Note that it does not say that the body type/outward appearance HAS to change.
They also state that the guidance is not prescribed in law - in other words they are making it up as they go along throwing out statements such as " their understanding of the law" when there is no law!

 

[oldiebut goodie]

Also see Motor caravans: changes to construction requirements from 2012

The first paragraph:
"Construction and use, and lighting regulations
All motor caravans (also known as camper vans, motor homes, recreational vehicles) used on the road must comply with various rules about their construction. The motor caravan must be safe, in that it must be well-engineered so that it is not likely to fall apart or otherwise cause danger to other road users.

In addition, from 29 April 2012 onwards, new motor caravans have been required to be approved. This means that a government agency will need to sanction the design of new motor caravans before sales can begin.

Existing motor caravans, already registered with the DVLA, are not affected by approval. Likewise, conversions of registered panel vans into motor caravans are not affected by approval. However it remains the responsibility of the manufacturer / converter to produce a safe vehicle.

There seems to be a misconception circulating about a requirement for ‘crash tested’ beds or seats. This is not the case. The rules on MOT testing (annual test) are not changing. Only the rules applicable to the construction of new vehicles are changing."

Yet again no requirement for change of body type mentioned which reinforces the view that they are making up their own requirements.

 

[St4n99]

I have come across this response ( Motor Caravans - Minimum Requirement of a 2 ring cooking facility or microwave - a Freedom of Information request to Department for Transport) from DfT concerning requirement for 2 ring cooker which has an interesting sentence contained within:

"Thank you for your email of 15 April to Department for Transport (DfT) Freedom of
Information Team, which has been passed to the Driver and Vehicle Licensing
Agency (DVLA) to respond.

The guidance you refer to is not prescribed in law but has been established, by the
Department for Transport, to assist motorists when they carry out “do it yourself”
conversions of their motor vehicles into “camper vans”/ “motor homes”.

The importance of the guidance, particularly in relation to incorporating fitments to a
vehicle, is for safety not to be compromised but, there would be no concern if the
cooker comprised of either one or two rings and it has been fitted correctly.

The register maintained by DVLA is based on vehicles and their keepers. The
register is essentially maintained to assist with road safety, revenue collection, and
law enforcement, i.e. the person responsible for their day to day use and licensing on
the public roads. For these reasons therefore, DVLA is concerned that they are being
informed about changes as and when they occur, but in particular when the vehicle’s
body type and/or its outward appearance is changed. "

They also state that the guidance is not prescribed in law - in other words they are making it up as they go along throwing out statements such as " their understanding of the law" when there is no law!

So in my case as I haven't sent my v5 to DVLA yet , I don't have to as it's not the law , then I can just have modified van insurance , may cost more for insurance but not really wanting to send v5 away if there is no need , mines is already an M1 class on v5 so nothing really to gain ,would I be fine not to change mine and leave the v5 as is? Thanks for your input oldiebut goodie

 

[oldiebut goodie]

As you are already M1, as you say, there is no advantage to having motor caravan as body type as insurance companies will cover as a campervan without the V5 amendment. Not as easy to find the right insurance co. but they are out there. The insurance co. will usually need the same photographs as the DVLA did and you can agree a value reflecting the added internals. ( They are more accommodating than the DVLA )

 

[St4n99]

As you are already M1, as you say, there is no advantage to having motor caravan as body type as insurance companies will cover as a campervan without the V5 amendment. Not as easy to find the right insurance co. but they are out there. The insurance co. will usually need the same photographs as the DVLA did and you can agree a value reflecting the added internals. ( They are more accommodating than the DVLA )

Sounds like a plan , thanks for your response

 

[Grim Reaper]

I've noticed this on the BritStops website..

Unfortunately Brit Stops is not suitable for caravans, unconverted vans, cars or any form of tent. Your van should be classed as a "motor caravan" on your V5C document.

So van conversions are unable to use the BritStops network if they are just "Van with windows" on the V5
Does this count as discrimination? I can't help but keep going back to the bit on the DfT documents that says "All campervans, motor caravans and motorhomes fall into the DVLA category of ‘motor caravan’
How can they not follow their own requirements?

I've sent an email to BritStops to ask their view.

 

[j4ckal]

I can't help but keep going back to the bit on the DfT documents that says "All campervans, motor caravans and motorhomes fall into the DVLA category of ‘motor caravan’
How can they not follow their own requirements?

Yes the exact point I was trying to make a few posts up. It doesn't make any sense to me.
They came up with the body type category 'motor caravan' which includes, according to them, campervans. Obviously it doesn't now though?

 

[oldiebut goodie]

I can't help but keep going back to the bit on the DfT documents that says "All campervans, motor caravans and motorhomes fall into the DVLA category of ‘motor caravan’
How can they not follow their own requirements?

I cannot explain it to you yet again! I have explained it several times now.

 

[oldiebut goodie]

I really don't know as the document seems to have been cobbled together by a tribe of monkeys! I have attempted to wander through various EU directives but have found nothing as yet concerning body type. It is most probably buried in a UK SI somewhere, it is just a case of finding it ( if it exists).

I have searched through SIs back to 2017 and no sign of anything, it is improbable that there is any amendment to legislation requiring body type to be changed.

The appropriate legislation is SI :-

S T A T U T O R Y I N S T R U M E N T S
2002 No. 2742
ROAD TRAFFIC
The Road Vehicles (Registration and Licensing)
Regulations 2002
Made - - - - - 4th November 2002
Laid before Parliament 8th November 2002
Coming into force
Except regulations 15(3) and
20(4) and (5) 30th November 2002
Regulations 15(3) and 20(4)
and (5) 7th April 2003
ARRANGEMENT OF REGULATIONS

relevant section is:
PART IV
NOTIFICATION AND CHANGES
Notification of an alteration to a vehicle
16.—(1) Where any alteration is made to a vehicle so as to make any of the particulars set
out in the registration document incorrect, the registered keeper shall deliver to the Secretary
of State—
(a) notification of the alteration;
(b) except where the registration document is lost, stolen or destroyed, the registration
document.
(2) If the alteration makes any of the particulars shown on the vehicle licence or nil licence
incorrect, the registered keeper shall also deliver to the Secretary of State the appropriate
licence, unless it is lost, stolen or destroyed.
(3) The Secretary of State may require the registered keeper to furnish such evidence as he
may reasonably require to show that the alteration has taken place.
(4) On receiving notification under this regulation the Secretary of State shall, subject to
regulation 15, if he is satisfied that the vehicle has been altered in the way notified to him,—
(a) record the alteration in the register;
(b) send to the registered keeper a new registration document showing the correct
particulars; and
(c) in a case falling within paragraph (2), send to the registered keeper a new vehicle or
nil licence showing the correct particulars.

 

[oldiebut goodie]

Section 15 referred to above:

Issue of new registration document
15.—(1) Before issuing a new registration document in respect of a vehicle under any
provision of these Regulations, the Secretary of State may require the keeper of the vehicle to
satisfy him by the production of the vehicle or other suYcient evidence that the vehicle—
(a) accords with the particulars furnished when a vehicle or nil licence was last applied
for in respect of it; or
(b) is the registered vehicle.
(2) The Secretary of State may refuse to issue a new registration document in respect of a
vehicle if he is not satisfied as mentioned in paragraph (1).
(3) The provisions of Schedule 3 shall have eVect in relation to the issue of a new registration
document in respect of a vehicle (in this regulation and in Schedule 3 called “the relevant
vehicle”) where—
(a) the relevant vehicle falls within category M1 of Annex II to Council Directive 70/156/
EEC(a), and
(b) either an insurer has informed the Secretary of State that it has decided to pay the
value of the relevant vehicle to the owner in preference to paying for the cost of
repairing it or the registration document has been surrendered to the Secretary of
State under regulation 20(5).
(4) For the purposes of paragraph (3) and Schedule 3 the return of a registration document
for a vehicle registered in the NI records in accordance with regulation 18(2)(b) shall be taken
to be the issue of a new registration document.