An extra £120 Road Tax on Motorcaravans

[Robingreathead]

 

 

Many who bought new vans last year and come to renew their road fund license will find that they have to pay £300 instead of the normal £180. Their vehicles have been registered as Diesel Cars TC49 rather than the previously used tax class Private Light Goods TC11, even though on their registration document the body type is clearly listed as motor caravan.

I rang Murvi to question this and was told it was nothing to do with them, it was the vehicle manufacturer VW who decides the appropriate tax group. Look up the DVLA website and one finds that ‘These rates apply to cars that have been type approved within category M1 of Annex 11 to Council Directive 70/156/EEC and have been registered on the basis of a type approval certificate that shows its carbon dioxide emissions level in terms of grams/km driven’.

I am told some converters/dealers are pushing for a review of this, among them Bilbo and Autosleepers. I get the impression that at present only VW T5’s converted using the ‘motorcaravan base’, supplied as such to approved converters by VW are affected, but please tell me if this is not the case. How this differs from the Kombi I do not know. There is also the suggestion that motorcaravans built using the ‘window van base’ which again has a different spec can be taxed as PLG and not Diesel Car. It seems ridiculous that because bits are added by the manufacturer instead of the converter it changes the taxation class.

Obviously it is not in the converter/dealers interest to bring the matter to the attention of the purchaser although it is annoying to find out a year later.

Beware all those who feel it cannot affect them. It is but a small step for our former Chancellor, Tax Stealth Brown, to redesignate leisure vehicles and base their road tax on emissions under the guise of boosting his green credentials while leaving commercial vehicles on a light goods category to avoid upsetting the business sector. Anything, diesel or petrol, taxed on emissions criteria with over 225 gram/km pays £300 while Private Light Goods, which is based on engine capacity paying only £180 with anything over 1549cc

 

[Derek Uzzell]

An intriguing one this...

 

My own imported Hobby, UK-registered in July 2005, is classified on its Type Approval Certificate of Conformity (CofC) as being in category M1. The emission data section on the CofC includes information on the levels of carbon monoxide, particulates, etc. on a g/km basis, but makes no mention of carbon dioxide. Presumably this was because the type of chassis/motor combination on which the Hobby is constructed - a 'light commercial vehicle' diesel-engined Ford Transit - fell outside the requirement for CO2 measurement at the type approval stage. Because the Hobby had a revenue weight of no more than 3500kg and could not be categorised for UK registration via its CO2 emissions, it was registered in the 'catch all' Private/Light Goods Class.

 

Murvi's suggestion that "it was the vehicle manufacturer VW who decides the appropriate tax group" is perverse. It may well be true that the VW panel-vans/chassis that UK converters are using for their motor caravans have CofCs that include CO2 emission measurements, but it's the responsibility of UK DVLA local offices to decide in which Vehicle Excise Duty category to place those motorhomes.

 

There is a natural tendency to feel that the UK's vehicle registration system should be rational and fair, but this is misguided. The system just IS and, because it's forever being tweaked according to governmental whim, it's bound to throw up anomalies and conflicts that get up motorists' noses and lead to non-standardisation in the way vehicles are categorised at the UK-registration stage. There have been examples of the latter described on this forum where 'personal' importers of over-3500kg motorhomes have had devilish difficulty getting them categorised correctly.

 

As far as I'm aware, where UK-registration is concerned, 'motor caravans' continue to be exempt from Type Approval requirements. If this is so, then one might think this should be the overriding factor, rather than what's on the motor caravan's CofC.

 

What I'm suggesting is that, when a Form V55/4 (Application for a First Licence for a New Motor Vehicle and Declaration for Registration) is submitted to a DVLA local office, if that form indicates the vehicle is a "Motor Caravan" and is "Exempt" from Type Approval, then the vehicle should immediately be 'classed' as Private/Light Goods (up to 3500kg revenue weight) or Private/HGV (over 3500kg). Basically, because of the block-exemption for motor caravans, all emissions data on the motor caravan's CofC becomes irrelevant where assignment of classification is concerned and it's just the weight that counts.

 

This, of course, is an interpretation of UK-registration rules that is advantageous to motorcaravanners. However, if we accept that the introduction of Graduated Vehicle Excise Duty (GVED) based on vehicle emissions was a 'good thing' environmentally (the 'greener' your vehicle, the less VED you pay), then it's extremely hard to argue the toss if the DVLA takes the stance that, should CO2-emission measurements be present on a motor caravan's CofC, these data must take priority when the vehicle's VED category is being assessed.

 

Personally, I don't believe we are heading for a situation where the VED of 'motor caravans' will be specifically calculated on CO2 emissions and the VED of light goods vehicles (LGVs) won't. I think it's far more likely that, if CO2 emission measurements are available to the DVLA when a vehicle is first registered, then those data will be used to assign the VED Class irrespective of whether the vehicle is a motorcaravan or LGV. (Basically, EVERYBODY will pay more!) But that's been on the cards ever since GVED was introduced in this country.

[Brian Kirby]

Is the clue not in the actual T5 variant that has been converted?  I, too, was puzzled, but on re-reading Robin's post, he refers to his van being on VW's "caravan base" chassis (effectively, I believe, a stripped out Kombi). 

The Kombi is, in effect, a minibus, so presumably has been type approved as a car.  I think what Murvi are saying (rightly or wrongly) is that an EC type approved car cannot be subsequently re-designated as a van, and so transferred into the PLG category.  The Kombi variant has been crash and emissions tested as a car, so a car it must remain.

Again from Robin's post, it seems that had the T5 variant on which his van is based been EC type approved as a panel van, and so tested etc. as a van, it would remain eligible for UK registration under the Private/Light Goods registration category. 

It seems buyers of T5 based motorhomes need to ascertain whether the base for their conversion has been EC tested and approved as a car, or as a van.  Notwithstanding, in relationship to the cost of T5 based motorhomes, an extra £2.50 per week in road tax seems unlikely to sway many buyers' decisions on which conversion to buy.

[Robingreathead]

Many thanks to Derek Uzzell for his information. It is most appreciated.

I had always assumed that it was the responsibility of the supplier [garage/dealer/converter], of the new vehicle to register the vehicle with the DVLA, unless it was imported by an individual, in which case it was the responsibility of that individual. It is indeed perverse, to use Derek’s expression, that converter/dealers having been registering motor caravans as Private Light Goods for years allow themselves to be high jacked into using another tax class without apparently so much as a squeak.

I do not know how many vehicles are involved, but having spoken to a number of converters the majority acknowledge that the problem exists.

I did however speak to a local converter today, who has had one of his conversions reviewed in the MMM and who had not heard of this problem. All of his VW T5 conversions are taxed as Private Light Goods.

Information and comment from forum members is appreciated.

In reply to Brian Kirby.

The converters maintain that these base vehicles supplied to the trade [bilbo, Auto-Sleepers, Murvi etc ] are specifically for conversion to motor caravans and in consequence not ‘a stripped out vehicle’.

 

[Mel E]

I think this is just another classic case of the DVLA 'getting it wrong'.

 

All vehicles shown on the V5 as motorhomes or motor caravans with a MAM/GVW of up to 3500Kgs are taxed identically to LCVs (Light Commercial Vehicles) and the CO2 emissions do not apply. If over 3500 Kgs MAM, thyey continue to be taxed as Private HGV and again CO2 does not apply.

 

In all but one other respect, they are treated as cars - same MoT, etc., - and not as LCVs.

 

The one exception is that motorhomes with an unladen weight exceeding 3050 Kgs are subject to LCV speed limits, which are 10mph slower than for cars on single and dual carriageways (i.e, 50mph and 60mph respectively). Many 3500 KG motorhomes are affected, though how your average PC Plod discovers what your vehicle's unladen weight is is altogether another question - it is defined as the empty weight without driver, fuel or water or removable loose tools and equipment. It is not shown anywhere on the vehicle.

 

Mel E

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[johnsandywhite]

*-) It's crazy isn't it? My piddly little Fiat 1.9 Dethleffs is taxed at £185 whereas my 7.5 Newmar is taxed at £165. *-)

[W3526602]

Hi,

 

The vehicles weight will be recorded on the V5 and on DVLA computer records. At sometime (already?) the roadside cameras will be able to access that informaton.

 

Some small vans are registered as "car derived" and they can travel at the same speed as cars. But similar vans of the same make and model are not registered as "car derived" and their drivers can be prosecuted for travelling faster than commercials are allowed.

 

I have noticed that the V5 now asks for your driver number when changing a vehicle to your name (This is voluntary, though I'm not sure if they tell you). I suppose the cameras could be programed to check if your licence allows you to drive that particular class of vehicle. Naw...thats stretching it too far...this week.

 

602

[Derek Uzzell]

Mel E says - "All vehicles shown on the V5 as motorhomes or motor caravans with a MAM/GVW of up to 3500Kgs are taxed identically to LCVs (Light Commercial Vehicles) and the CO2 emissions do not apply. If over 3500 Kgs MAM, they continue to be taxed as Private HGV and again CO2 does not apply."

 

There is a subtle difference between the UK Taxation Classes potentially available for 'private use' up-to-3500kg MAM vehicles or for 'private use' vehicles over that weight - there is only one logical Taxation Class (TC10 - Private HGV) for the latter category. There are just two criteria for a vehicle to be selected for TC10 - it must have a revenue weight (MAM) in excess of 3500kg and be used privately. As Mel rightly says, CO2 (or any other exhaust emissions) is not a selection factor for TC10, nor are the type of fuel used by the vehicle, maximum vehicle weight, etc. As johnsandywhite highlights, the current situation is that a motor caravan registered in TC10 will attract a Vehicle Excise Duty (VED) annual rate of £165, while one registered in Class TC11 (Private/Light Goods Vehicles) will have an annual VED of £180. That an owner of a sub-2-tonne, 16' long Romahome will pay £15 more VED per annum than the owner of a 10-tonne-plus, 39' long Damon RV will seem to most people a mite odd, but just proves that the UK system has no place for 'fairness' and is tolerant of anomalies.

 

On 1st March 2001 a Graduated VED system was introduced with three new Taxation Classes (TC48, TC49 and TC59) for up-to-3500kg MAM 'passenger-carrying' vehicles (in simplistic terms - 'cars'). Class selection criteria comprise the type of propulsion fuel used by the vehicle (TC48 - petrol, TC49 - diesel, TC59 - other/hybrid), the vehicle 'type' and the vehicle's CO2-emission value, with these data being obtained from the vehicle's Type Approval Certificate of Conformity (CoC).

 

To be placed in one of these 3 classes an up-to-3500kg MAM vehicle must a) have Type Approval, b) be Type Approved as Category "M1", c) be powered by the appropriate fuel(s) and d) have a measured CO2 emission figure on its CoC. Assuming these criteria are met, the vehicle's annual VED will then be derived from a 7-step table in the appropriate 'fuel type' Taxation Class and (as Robingreathead said), for TC48 and TC49, the top step currently attracts a VED of £300.

 

If, however, any of these criteria cannot be met, then the vehicle 'drops out of ' the Graduated VED system's scope and falls into the now-archaic Private/Light Goods (TC11) Class.

 

Historically, motorcaravans have been exempt from Type Approval-related requirements where UK vehicle registration is concerned. Presumably this is because, being the offspring of a shot-gun marriage between a delivery van and a caravan, few (if any) 'complete' motor caravans actually had Type Approval. However, things have begun to change, and a number of motorhome manufacturers now produce vehicles that are fully Type Approved.

 

As I said earlier, my 2005 Hobby is a case in point and, when I read the DVLA's registration guides and glanced through my Hobby's Type Approval documentation, I thought it might well end up assigned to Class TC49. It was only later, when I was transferring the emissions data from the Hobby's CoC to the UK-registration application form, that I realised there was no CO2 figure given and that this would force the vehicle into Class TC11.

 

Robingreathead's postings indicate that motor caravans that a) are Type Approved, b) are Category "M1" and c) have a CO2 measurement on their CoC are now being submitted to the DVLA for UK registration. (Whether this will be normal henceforth I don't know, and I'm not going to speculate.)

 

We now have a logical dilemma. If the vehicles were 'cars' (and, as Mel E observes, 3500kg MAM motor caravans are, in many respects, already treated by the authorities as such), then there's no doubt that the Graduated VED system should be used to assign the rate appropriate to the vehicles' propulsion-fuel and CO2 emission level. And if that turns out to be £300 annually, then tough luck!

 

To avoid this, it might be argued that motor caravans are somehow 'special' and that their original exemption from Type Approval for UK-registration purposes should be maintained indefinitely, overriding the Graduated VED rules. However, if I were in the DVLA, I'd be asking myself "Why?" and I can't really come up with a plausible answer.

 

I fully accept that, unless Graduated VED could be applied to ALL 3500kg MAM motorhomes from a set date, there would be serious inequalities VED-wise between vehicles that met the Graduated VED criteria and those that didn't. But, as there's already a precedent for VED inequality with up-to- and over-3500kg MAM motor caravans, that's hardly an overpowering reason to shy away from moving motorhomes from their slot in the out-of-date Private/Light Goods Class into the modern emission-sensitive Classes. Besides which, it's bound to produce more income for the Treasury and might even result in an increase in my State Pension when (if?) I eventually get it!

[HBjour]

I tried to register my imported private personal car (Mitsubishi Spacewagon 2002) last Thursday, they asked me for £180 for Road Tax annual fees. Unfortunalty I had no insurance certificate that day therefore I returned back to the DVLA local office today and instead of 180 they charged me £300 and insisted this is the correct one. What do you think abou this?

[W3526602]

Hi,

 

Obviously one of the DVLA staff got it wrong...but which one?

 

Somewhere in VERA it says that over, or under payments cannot be corrected after 12 months. So you have a little time to argue.

 

602

[Derek Uzzell]

HBjour:

 

An annual VED of £300 indicates that your imported Mitsubishi has been registered in Band G of either Taxation Class 48 (Petrol car) or Taxation Class 49 (Diesel car).

 

Band G relates to Type-Approved passenger vehicles in the 'M1' category with a revenue weight up to 3500kg and with a CO2 Emission Figure above 225g/km. The CO2 Emission Figure is normally recorded on the Type Approval documentation submitted to the DVLA at the UK first-registration stage. Presumably, in your case, the DVLA were able to find the CO2 figure in the documentation you provided and have used it to assign your vehicle to Band G of TC48 or TC49.

 

The 2002-model Space Wagon was a large people-carrier and (I believe) was usually fitted with a 2.4 litre petrol engine and auto-box, so a highish CO2 figure seems plausible.

 

If you intend to contest the DVLA's decision, you'll need to ask the following questions:

 

1. Is your car Type-Approved as 'M1'?

2. Is it below 3500kg maximum overall weight?

3. Does it have a CO2 Emission Figure (measured as part of the Type Approval process) above 225g/km?

 

If the answers to these 3 questions are all "Yes", then an annual VED of £300 is correct.

 

The usual reason for an up-to-3500kg, 'M1'-category passenger vehicle being registered as TC11 (Private/Light Goods Vehicles) and attracting a current annual VED of £180 is that measurement of CO2 emissions has not been carried out during the vehicle's Type Approval and is, consequently, not shown in its documentation. (This seems to be the norm with sub-3501kg motorhomes.) With no CO2 Emission Figure to work from, the DVLA have no option but to place the vehicle in the 'catch all' TC11 Taxation Class.

[HBjour]

Thank you very much indeed,

 

Yes my vehicle is a 7 seater automatic 2.4. and the CO2 emission is about 3.1, which means £300 supposed to be correct, according to Derek clarification.

[robin]

So... if I understand this correctly ..

 

My 2006 Renault MVW 3500k is Class TC11 (Private/Light Goods Vehicles) and has an annual VED of £180. (incidentally £15 cheaper than my Euro diesel car).

 

If I replate it at 3900k (no modifications are required to do this - I believe) then it will classed as Private Heavy Goods TC10 and will attract a VED annual rate of £165.

 

I have just checked the V5 Registration Certificate and hey -- Wheelplan = 3-Axle-Rigid body. >:-)

[Mel E]

I suspect that this problem with some VWs is arising because the dealers are completing the DVLA registration form wrongly.

 

As Derek has said, the form has spaces for the CO2 figures, etc. But ALL motorhomes are exempt from Type Approval, so, even if you have a ECWVTA Certificate for the vehicle, it should be ignored and the CO2 part of the form left blank.

 

If you put in a CO2 figure, they will likely ignore the motorhome classification and charge you accordingly. Remember that these people register over 2 million new vehicles a year, only a few thousand of which are motorhomes - so many of the clerks don't see a motorhome form from one year end to the next.

 

Mel E

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