DVLA Call for Evidence - All Questions

The full HCVA response will be shared with, and submitted on behalf of, its members. It contains greater detail, including a number of examples of evidence to support comments, and makes suggestions to assist the DVLA’s decision-making process, as requested by the DfT. However, if you would like to answer on your own behalf, the information below is intended to provide you with useful background information.

Postal deadline circa 30th June. Online closing date - July 4th 2024

• Snap Survey

• Visit Call for Evidence Overview

• Response Form (PDF) 

For the easiest and quickest response we recommend the Snap Survey option above. You don't need to answer all the questions, so you can just scroll through to the key ones we've suggested below.

The DVLA Survey is complex: it’s important to restrict answers to the questions asked, and only answer those which you want to answer. 

The final question opens the floodgates to include all the issues that have not been addressed in the detail questions before – so if you have limited time, you may be best to go straight to the final question, as it’s the most important. You don’t want to run out of time before you get there…

Almost all of the questions invite the respondent to accept the status quo of current DVLA classifications. This is not helpful – we must convince DVLA to abandon most of the categories their document refers to, and replace them with a new streamlined approach that will both reduce their workload and improve treatment for historic vehicle owners. Note also that DVLA exists to curate vehicle records – not safety. DVSA has sole responsibility for roadworthiness standards and we strongly disagree with DVLA assuming any responsibility for these.

Key to our response is the fact that the UK registration system, now over 120 years old, represents a vital historical resource that should be preserved at all costs. De facto, this means that all vehicles should retain their original registration numbers irrespective of restoration or modifications.

Currently DVLA treats restoration, rebuilding and reconstruction of historic vehicles as a detrimental step that is likely to trigger removal of the original registration number and issue of a DVLA VIN and Q-plate. Modifications - sometimes as simple as drilling a hole into the chassis or bodyshell - are also triggering the same result. This approach is completely misguided and extremely detrimental to the historic vehicle industry and the entire movement, as well as the value of the registration system to authorities and as a historical record. We feel it is vital to target our responses to correct this approach.

HCVA responses for background and guidance purposes

Please read in conjunction with the Snap Survey or PDF

3.1 The HCVA’s opinion is that a Classic vehicle is one where enthusiasm for it is such that owners gather in groups or clubs to help each other restore, preserve and enjoy it, or specialist businesses form to support its continued use. It is not an attribute simply of vehicle age.

Historic vehicles are vehicles preserved for future generations to enjoy as part of our industrial and cultural heritage. DVLA uses a rolling cut-off of 40 years old for Historic VED classification and MoT Exempt status. This is useful but it is worth noting that most other countries follow the FIVA recommendation of 30 years old for Historic status.

The definition of a ‘classic’ vehicle is not significantly different from historic, but there is no fixed age cut-off.

The definition of a ‘classic’ vehicle is not significantly different from historic, but there is no fixed age cut-off.

3.2 The existing Historic VED classification and MoT exemption was meticulously evolved with significant stakeholder engagement and is still working well in most instances, and helps to ensure the future preservation of historic vehicles. The application process could be improved with a more targeted form for imported vehicles than the generic V55/5.

3.3 The existing registration system dates back to 1903 and already provides the facility of a series of age-related registration numbers specifically for historic and classic vehicles, therefore changing it is considered to be counterproductive and unnecessary.

3.4 Safety checks are a DVSA issue, not DVLA. HCVA is already preparing an optional test, led by in industry and working closely with DVSA.

3.5  Yes. Restoration of an existing historic vehicle, with new replacement parts where needed, is a positive action that enhances the safety and historical value of the vehicle. It should not trigger changes at DVLA. Construction of a vehicle without previous history/registration from old parts is entirely different and we suggest that these could be handled as a Built-Up Classic Vehicle by DVLA. See 3.6

3.6  HCVA considers that this guidance would benefit from revision. The HCVA are proposing that this category could be renamed Built-Up Classic Vehicles, potentially with sub categories that recognise and differentiate vehicles reconstructed from original parts from various vehicles and those examples built up using recently remanufactured parts.

3.7 Use of the term ‘reconstructed’ should be reviewed to avoid confusion. The HCVA are proposing that this category could be renamed Built-Up Classic Vehicles, potentially with sub categories that recognise and differentiate vehicles reconstructed from original parts from various vehicles and those examples built-up using recently remanufactured parts.

3.8 If the proposed Built-Up Classic Vehicles category was considered and adopted, there could be some further simple categories, as successfully operated by the VSCC for many years, which differentiate between the number of original parts retained in such a vehicle.  

Some parts that might be incorporated could be more recently manufactured, which should not alone be a penalty if they are to a period-correct specification. This subject requires further investigation by an independent stakeholder panel drawn from members of the HVUG, working alongside DVLA and DVSA as appropriate.

3.9 The HCVA Selected: ‘Specific to vehicles not previously registered’

Reasons: The Built-Up Classic Vehicles category should not be applied to restored/rebuilt/reconstructed vehicles with an existing identity: these should retain their authentic original identities.

3.10  Historic and Built-Up Classic are defined above. Replica vehicles are constructed with new or used/reconditioned parts to closely resemble a Historic vehicle: some could fall in the proposed Built-Up Classic category, with others recorded as Kit-built or Kit converted. New vehicles built to a Historic design by the original vehicle manufacturer are not Replicas: these deserve a new category of Continuation vehicles and have new registration numbers.

3.11 DVLA does not need a “rebuilt vehicles” category. Where an existing vehicle is rebuilt (i.e. restored) and components are renewed due to wear or corrosion, this is a positive enhancement of its continuing history and should not affect the DVLA record.

3.12 The HCVA’s opinion is that the guidance is incorrect. There is no, as suggested, ‘fine line’ and the vehicle’s identity is not brought into question by rebuilding or altering it, or indeed drilling, cutting or welding (so repairing) a chassis or monocoque bodyshell, as DVLA are currently suggesting. The degree of renovation required depends on the degree of degradation the original vehicle has suffered: this is part of the vehicle’s continuing history, and DVLA should not remove an original registration or VIN (chassis number) from a vehicle due to it being rebuilt.

3.13 No. This is completely unnecessary.

3.14 DVLA only needs to be informed where changes are made to affect the details recorded on the V5C, such as a change of colour, engine number, engine size, fuel type or body configuration.

3.15 The HCVA Selected: No

Modifications to the chassis/frame/monocoque are not relevant to vehicle registration, only to vehicle safety which is policed by DVSA not DVLA. The HCVA are proposing that by simplifying the categories, there is no need for the rebuilt category and that it should be encompassed, when applicable, within the proposed new Built-Up Classic Vehicle category. See 3.11 & 3.12

3.16 The identity of a vehicle should not be affected by modifications made to the chassis, monocoque or frame as part of the rebuilding of an existing registered (UK or imported) vehicle. This should be considered as a continuation of its existing history.

3.17 DVLA has no responsibility for informing consumers if a vehicle has had major rebuild or restoration work. Restoration represents positive enhancement to the vehicle, and is celebrated and usually advertised, not hidden, by vendors.

3.18  The HCVA have selected: ‘There should be a specific process for assessing restored vehicles’

However, the HCVA’s opinion is that the question should also give the option “There should be NO specific process for assessing restored vehicles”. There is no need for DVLA to assess restored vehicles, as restoration of an existing registered vehicle should not affect its entitlement to its authentic original identity or registration.

3.19 A restored vehicle is an existing and authentic vehicle which has had corrosion, wear and damage from decades of use and neglect rectified by repair and renewal of components or structure. Restoration may take place multiple times in the lifetime of a registered vehicle, and is a necessary and positive part of that history.

3.20 There is no need for separate policies.

3.21 Modifications made to the existing chassis, frame or monocoque bodyshell should not affect the registration entitlement, as long as it forms part of an established vehicle history.

3.22  DVLA has no responsibility for informing consumers if a vehicle has had major rebuild or restoration work. Restoration represents positive enhancement to the vehicle and is celebrated and usually advertised, not hidden, by vendors.

3.23 The current guidance is still relevant.

3.24 Reconditioned or remanufactured components should be considered the same as brand new components if supplied by a reputable specialist supplier.

3.25 This is a matter for DVSA and should not affect DVLA procedures.

3.26 The current system is long-established and seems to work satisfactorily

3.27 It is not necessary for the V5C to indicate this.

3.28  It is not necessary for sources to be shown on V5C. A responsible builder will keep a file of all details with the vehicle as this will enhance its value when sold on. The IVA or MoT test will assess the safety of components, which is not a concern for DVLA.

3.29 The HCVA’s opinion is that the term Radically Altered should only apply to vehicles so drastically altered that the original Historic vehicle has ceased to be. For example, a vehicle authentically converted from a closed to an open vehicle to the same pattern as originally offered by a manufacturer should not be considered as being ‘radically modified’, as currently is being suggested, although the fact that the vehicle was built new to a different body configuration could be recorded in the notes section of the V5C. The subject is complex and the point at which that line is crossed should be decided by a cross-functional stakeholder group of industry and associated experts drawn from the HVUG alongside DVSA and DVLA. The current points system is potentially confusing and open to different interpretation, hence the need for further consultation and a thorough review with the agencies and the stakeholders working together.

3.30 Current guidance is not relevant because continuous history should always be the primary consideration when assessing radical alterations and their impact on a vehicle’s identity. Where there are structural or safety concerns with an individual radically altered vehicle, DVSA should adjudicate. The reasoning behind this stance is that the proper care (including modification) of a vehicle’s automotive heritage should not result in the loss of its identity.

3.31 DVLA needs to be informed only where details recorded on the V5C become incorrect and need to be updated.

3.32  The main emphasis should be the continuation of a vehicle’s existing identity and history. Alterations are often applied (and have been for many decades) to the chassis/frame, bodyshell, power unit, transmission, suspension and brakes. The term Radically Altered should only apply to vehicles so drastically altered that any connection with the original vehicle has ceased to be. See 3.29 & 3.30.

3.33 As far as registration is concerned, existing rules for change of propulsion should suffice. The vehicle taxation class should be changed appropriately and all changes marked on the V5C.

3.34 Safety is critical and existing DVSA systems should be fully utilised for Historic vehicle conversions, including r100.01 approval. HCVA has introduced a code of practice for electrification incorporating r100.01 approval and many other safety considerations. It is vital that a Historic vehicle converted to electric propulsion is accurately recorded as such on the V5C to enable First Responders to be aware and take appropriate precautions.

3.35 Modifications to the chassis/frame or bodyshell of an existing vehicle should not automatically trigger a change of VIN or registration number. See 3.29 & 3.30

3.36 We agree that a Q registration should only be issued where the original identity is unknown or cannot be determined. DVLA’s priority should be to keep existing vehicles authentically registered, with difficult cases adjudicated by an expert independent stakeholder panel made up of HVUG members. See 3.29 & 3.30.

3.37 HCVA selected: No

Modifications to the chassis/frame or monocoque of an existing authentic vehicle should not result in the removal of the vehicle’s identity. See 3.29 & 3.30.

3.38 It is not the DVLA’s responsibility or remit to inform consumers that a vehicle has been modified, beyond changing details recorded on the V5C as required.

3.39  Historic and classic vehicles that have been rebuilt or restored should retain their original VIN/chassis/frame number and registration number as the default position. The only justification for rescinding a registration number is if another vehicle has, or could have, a more valid claim to that registration number. In such a case, this should be adjudicated by industry specialists, clubs and from expert inspection. An age related registration number should only be issued to a rebuilt or restored vehicle in the absence of a verifiable pre-existing history, or at first registration in the case of an imported vehicle. Q- registrations are not appropriate for rebuilt or restored Historic or classic vehicles.

3.40 A DVLA generated VIN should be allocated to Built-up vehicles without a valid claim to a supporting identity and not using a prerequisite number of period-original parts. In the past, there was an option of a bespoke chassis numbering system, offered to a small number of clubs in relation to Built-up vintage vehicles.  The law requiring a stamped in 17-digit unique VIN only applies to vehicles constructed since 1981. Previously it was not unusual for different manufacturers to use similar or even the same chassis/frame numbers  as each other and this has not previously been a problem for DVLA records.

3.41 Pre-1981 vehicles did not have a unique VIN and their identification number was not always stamped on a solid part of the vehicle. Continuous history kept with the vehicle and by Industry, manufacturers, archives and owners’ clubs is often adequate to confirm identity in these cases. Where doubt remains, an independent stakeholder panel consisting of industry and marque experts drawn from the HVUG along with DVLA colleagues should be convened to arbitrate. An original registration number should not be removed unless another vehicle has a more valid claim to it.

3.42 The HCVA selected: No

Where a vehicle has a continuous history, the HCVA OEM members confirm that they have no concerns with original VINs and chassis numbers being retained or restamped, as long as the original component or plate bearing that number is verifiably destroyed or certified as missing. This policy should also apply to replacement like for like chassis data plates.

3.43  The HCVA selected: No

A DVLA VIN should not be issued where an original chassis or monocoque bodyshell with registration history has been modified or replaced. The replacement chassis should be clearly stamped with the vehicle’s original identification number (if any) and any removed original chassis remnants should be permanently retained with the vehicle or destroyed. 

4.1 The HCVA selected: Yes 

The German registration authority, for example, does not consider conversion from a fixed roof to a convertible to affect a vehicle’s original identity or Historic vehicle status. See 3.29

Many countries follow the recommendation of FIVA, the international body representing historic vehicle owners, that Historic status be awarded from 30 years old, not 40 as in UK.

5.1 The HCVA selected: Yes 

At present, DVLA are requesting our help and feedback in recognition that there is a problem affecting owners of Historic vehicles in the UK. They are currently referring to a policy written about 40 years ago and interpreting it (as confirmed within the Call for Evidence Guidance) to such a literal sense that drilling a hole in a floor , for safety reasons, to then fit seat belts or a roll cage, will result in an authentic original vehicle identity being made void and a Q plate, DVLA generated VIN and the need for an IVA test to be applied.

The process required to help the DVLA to be able to correct this position is via the Call for Evidence, which is the result of over three years of lobbying by the HCVA and associated organisations.

Therefore, DVLA should absolutely implement this option, using stakeholders represented in the HVUG as its basis and additional experts when deemed necessary.

DVLA themselves successfully defended, as upheld in the Court of Appeal (Seddon vs DVLA in 2019) that they do not have the the expertise on individual vehicle details that exists among specific vehicle restoration specialists and historical experts.

5.2

DVLA’s current categorisation of Historic vehicles as:

To many, this can be confusing and leads to incorrect allocation of cases. It is our recommendation that DVLA in future explores and considers potentially using the following categories only –

DVLA’s priority should be to keep vehicles registered, NOT change or withdraw registrations at will.

When assessing a claim to an original, currently lapsed, registration, DVLA should not insist on provision of a historic RF60 log book or old MoT certificate.

When assessing imported classics, DVLA should accept vehicle manufacturer records when issuing an age-related registration number.

When assessing imported classics, DVLA should be sensitive to the different use of terminology by foreign registration authorities.

DVLA should reintroduce the scheme allowing owners to obtain copies of past registration records for Historic vehicles.

DVLA’s current V894, V672/1 and inspection route, instigated without giving any justification, is onerous and is inconsistently applied and followed. 

• Snap Survey

• Visit Call for Evidence Overview

• Response Form (PDF) 

Postal deadline circa 30th June. Online closing date - July 4th 2024