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Motorhome licensing – road tax

Derek Uzzell

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Beginning on Page 183 of the latest (March 2016) issue of MMM magazine is an Owner Report article about a 2013 Concorde Credo motorhome that is Fiat Ducato-based and fitted with a 3.0litre 180 Multijet Power motor and Comfortmatic transmission.


What may be of interest is that the owner mentions that the motor’s CO2 emissions figure is 226g/km and that this figure was used when the motorhome was UK-registered. Consequently the cost of first-registration was £840, with £475 for subsequent years.


This earlier discussion relates to the DVLA’s current position regarding licensing of motorcaravans




The Credo is a large A-class design with AL-KO chassis and it seems unlikely that Concorde would have been able to provide an accurate post-conversion CO2 figure - so I suspect that the motorhome was incorrectly registered in 2013 and should have been classed as Private HGV. It’s impossible to say for sure, though, without having access to the vehicle’s documentation.


The moral of this tale is that buyers of new motorhomes should be careful to ensure that the vehicle is correctly UK-registered, and ‘self importers’ of motorhomes should be particularly wary.


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Wow ! That's some increase in road tax, would be a serious disincentive to purchasing this vehicle second hand, unless the owner can get it changed to PHGV, which is only 165 pounds a year. I will be checking the V5 of any van I intend purchasing. No emissions data please !
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I was under the impression that all new vans from around that period should have a co2 figure and this had to be entered on registration, and that around 2011 when our van was registered this was optional.

The CofC from Delheffs for our Globecar has the co2 figure, but was not registered.

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Effective from 1 August 2013 the DVLA introduced revised rules regarding motorcaravan licensing




but I’ve no idea how effectively those changes were advertised to motorhome dealerships at the time (or what steps were taken within the DVLA itself to ensure that the changes were fully understood).


The Credo motorhome was purchased from Southdowns Motorhome Centre (SMC) that is - I believe - the sole UK Concorde agent.


SMC also sells other motorhome brands (eg. Burstner, Carthago, Laika) that include large, expensive A-class models in their ranges and should thus be well aware of which UK licensing category such vehicles are normally put in by the DVLA. So it may be the case that Concorde did/does put a CO2 figure on their ‘post -conversion’ Certificate of Conformity (C-of-C). In the MMM article the Credo’s owner says that the CO2 figure is shown on the vehicle’s V5C document, which indicates that the DVLA got the figure from somewhere.


I guess if one is prepared to pay £100k or so for a vehicle the cost of UK-registration might not be of paramount importance. But if I’d been told that registration was going to cost £840 initially and near £500 annually afterwards, I’d have wanted to be very very sure that was correct.


The Owner Manual for a Euro 5 Fiat Ducato quotes a ‘mixed’ CO2 emissions figure of around 220 for the 3.0litre motor where a Maxi chassis-cowl is concerned, but there’s a footnote that "Such consumption is meant for vehicles before the conversion”. It may be that Concorde just copied the Fiat CO2 figure on to their C-of-C, or the DVLA used the Fiat C-of-C figure instead of the Concorde one, but it wouldn’t be easy to get the DVLA to change things now even if the Credo should have been differently classified back in 2013.

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  • 3 weeks later...

I decided to ask the DVLA to clarify their current rules regarding UK ‘first registration’ of motorhomes with European Community Whole Vehicle Type Approval (ECWVTA).


The rules are (apparently) as follows...


1: When a CO2 emissions figure is NOT present on the final stage Certificate of Conformity (CoC) for the finished motorhome, if the motorhome’s overall weight IS UP TO 3500kg it should be licensed in Tax Class 11 (Private/ Light Goods).


2: When a CO2 emissions figure is NOT present on the final stage CoC for the finished motorhome, if the motorhome’s overall weight IS OVER 3500kg it should be licensed in Tax Class 10 (Private HGV).


3: When a CO2 emissions figure IS present on the final stage CoC for the finished motorhome, if the motorhome’s overall weight IS UP TO 3500kg it should be licensed in the graduated tax class relating to its fuel (Diesel, Petrol or Alternative) and its rate of tax will depend on the tax class’s emissions ‘band’. Most motorhomes are diesel-fuelled and, consequently, would be assigned to Tax Class 49 (Diesel Car).


4: When a CO2 emissions figure IS present on the final stage CoC for the finished motothome, BUT THE VEHICLE’S OVERALL WEIGHT IS OVER 3500kg the graduated tax classes will be inappropriate as they apply only to vehicles weighing up to 3500kg. In such cases the motorhome should be licensed in Tax Class 10 (Private HGV).


Consequently, even if the Concorde-produced CoC of the “Credo” motorhome I mentioned earlier did carry a CO2 emissions figure , the vehicle should not have been UK-registered based on that figure because its weight (4500kg) excluded it from the graduated tax classes. Instead of being registered in Tax Class 49 with a Band L first-year tax rate of £840 and a subsequent-years rate of £475, the Credo should have been registered in Tax Class 10 (Private HGV) that had a tax rate of £165 in 2013 that has not been increased since.


The information the DVLA provided in 2013 regarding revised motorhome registration rules fails to mention the 3500kg weight maximum of UK graduated tax classes. I have suggested to the DVLA that it would be helpful if this oversight were rectified.



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Thanks for following this up, a very important piece of research and one that ought to be flagged up in mmm or to a wider audience.

Changing the tax band once allocated and getting a refund is no easy matter.

Could this be a "sticky" for all owners of new motorhomes to access?

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I’ll send a ‘letter’ to MMM about this.


I needed to email the DVLA three times before I could get an acknowledgement that the graduated VED classes should not be used for motorhomes over 3500kg in weight.


I suspect that the DVLA overlooked the 3500kg weight-limit of Tax Classes 48, 49 and 59 when they revised their attitude to motorhome registration in 2013 and it would appear that they (or anyone else) have not picked up on this since.


I don’t think there’s any set-in-stone reason why the current 3500kg threshold of TC 48, 49 and 59 should not be removed, and that would ‘catch’ all motorhomes with a CO2 figure on their converter’s CoC irrespective of their weight. It’s just that the current description of TC 48, 49 and 59 continues to include the 3500kg limit.


There’s nothing on DVLA Form V149 to indicate that the graduated VED classes 48, 49 and 59 have a weight-limit. This only becomes evident when DVLA leaflet V355/1 is consulted.


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It's worth noting that VW campervans cost more to tax than, say, a Ducato panel-van conversion - presumably because VW does include a CO2 emissions figure in the Certificate of Conformity.


Therefore, a 180 DSG 4-Motion T5.1, for instance, would cost a considerable amount to tax - upwards of £400, I believe, even though it's probably still more economical than the equivalent Ducato. I think our 140bhp manual Lezan used to cost around £280, even though it did about 36mpg.


Unjust - but something for prospective purchasers to bear in mind.

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We are changing our motorhome on Mar 1 to an Eldiss Accordo. We received the V5 this morning (it seems odd to get the log book before the vehicle but hey ho). It does list the CO2 and NOx and HC+NOx but not particulates. The taxation class is stated as Private Light Goods and body type as Motor Caravan. How this fits in with diesel car tax bands I know not, but will find out in Mar next year I guess.
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When a vehicle is first registered in the UK it will be assigned to one of the many Tax Classes (TCs) shown on the DVLA Form V149 that is in force at the date of the registration. The current (2015) version is here

Historically the DVLA registered motor caravans based on their ‘chassis weight’, with vehicles weighing up to 3500g being assigned to TC 11 (Private/Light Goods) or TC 10 (Private HGV) if the vehicle’s weight exceeded 3500kg.

With effect from 1 August 2013 the DVLA changed its stance and issued the following guidance:

"New Licensing Arrangements for motorhomes/motorcaravans 

From 1st August 2013 a change was introduced for the licensing of all vehicles type approved within the M1SP category and this includes motorhomes/motorcaravans. 

It is important to note that when licensing newly registered vehicles in this category for the first time, DVLA representatives should only be considering the Certificate of Conformity (CoC) for the final stage vehicle. Although, all other CoCs (ie first stage, second stage CoCs) relating to the vehicle must also be provided to the DVLA. 

Where original first or second stage base vehicles are converted by manufacturers to a motorhome, the conversion process will affect the original emissions figure stated by the first stage base vehicle manufacturer. 

Therefore, most motorhome/motorcaravan manufacturers/converters do not quote a CO2 emissions figure on the final stage CoC. Accordingly, the CO2 emissions field on the final stage CoC will normally be left blank when registering the vehicle via Automatic First Registration & Licensing AFRL or with a V55/4 form. 

Where no CO2 emissions are present on the final stage CoC for the finished vehicle it must be licensed in the Private Light Goods or Private Heavy Goods Vehicle taxation class, depending on weight. 

If however the motorhome/motorcaravan manufacturer/converter has stated a CO2 emissions figure on the final stage CoC for the finished vehicle then the motorhome/motorcaravan should be licensed in a vehicle taxation class based on its CO2 emissions. Where the CO2 figure is provided on the final stage CoC this will be captured and recorded on the vehicle record. 

If you are unsure as to which CoC covers the final stage approval for the finished vehicle it is the one which has the same type approval number as that stated on the V55/4 Registration form.”

A motor caravan that has European Community Whole Vehicle Type Approval (ECWVTA) - as will be the case with your Elddis Accordo - will have two Certificates of Conformity (CoC), one relating to the Peugeot Boxer chassis on which the Accordo is based and a 2nd CoC produced by Elddis and covering the vehicle after it has been converted. 

Where CO2 emissions are concerned, it’s what is on the converter’s CoC that matters to the DVLA. If the converter’s CoC carries a CO2 figure and the motorhome’s weight is up to 3500kg, the motor caravan should be assigned to TC 49 (Diesel Car) or TC 48 (Petrol Car) or TC 59 (Alternative Car). If the motor caravan weighs more than 3500kg or the converter’s CoC carries no CO2 figure, the historic weight-related rules apply and the vehicle should be assigned to TC 11 or TC 10.

Your Elddis Accordo has been assigned to TC 11 (Private/Light Goods). Although its V5C registration-document records ‘emissions figures’ it may be assumed that the DVLA has taken those data from the Peugeot CoC as, if there were a CO2 figure on the Elddis CoC, your presumably-up-to-3500kg-weight Accordo would have been assigned to TC 49 (Diesel Car).

At UK first-registration, once the DVLA has assigned a motor caravan to a particular Tax Class that’s the Tax Class the vehicle stays in ‘forever’, unless the DVLA can be persuaded that the vehicle was wrongly assigned. 

As your Accordo is in TC 11 (and as far as I’m aware that’s the correct Tax Class for it) it will continue to be taxed in TC 11 in the future. The emissions-related Tax Classes (TC 48, 49 and 59) will have no effect on this.
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The arrival of Euro 6 regulations could make it financially advantageous for motorcaravanners (as far as UK vehicle taxation is concerned) for an up-to-3500kg-weight motorhome to be assigned to an emissions-related Tax Class (eg TC 49 - Diesel Car) rather than to the traditional TC 11 (PLG).


For Ducatos fitted with the 2.3litre 150 MJ Euro 6 motor Fiat’s CO2 data range from 150g/km to 158g/km. In principle this could place Ducato-based motor caravans (3500kg maximum) with that powerplant in Tax Class 49 and in Emissions Band F or G.


Currently this would result in a first-licence and annual tax rate of £145 (Band F) or £180 (Band G). If the same motor caravan were registered in TC 11 (PLG) the current annual tax rate would be £230.

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