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Taxation Idiocy


bobalobs

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Hi,

 

I'll attempt to explain the reason given for the Mercedes RWD anomaly, (as it was explained to me, when testing such a vehicle for a forthcoming article).

 

The new taxation applies to those vehicles which are 3,500kg or below. The van we tested was 3,500kg, but, being on a Merc. RWD, (actually an RWD with 4x4 capacity added), didn't have the extra taxation - so Peter is quite right. And both test vans were the latest models.

 

Why? Apparently, because Merc. RWD's CAN be on chassis rated way above 3,500kg, so the RWD Sprinter base vehicle is exempt. Even if, as in our test van's case, it IS built on the 3.5tonne chassis.

 

The same applies (apparently), to the Iveco RWD. However, it seems that other base vehicles(including FWD Sprinters) have GVWs of 3,500kg, so aren't exempt.

 

And yes, I know, Fiats are often 3,650kg, downplated to 3,500kg - I can't explain why they aren't accepted, it is all daft!

 

So, it appears, a 2020 AutoSleeper Merc. coachbuilt owner won't pay the extra tax; his Peugeot AS counterpart will - as would the owner of an FWD Merc.-based van.

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brom - 2019-12-24 3:55 PM

 

...The new taxation applies to those vehicles which are 3,500kg or below...

 

Except (he said reasonably confidently!) it no longer does.

 

I refer you to the last four postings of this October forum thread

 

https://forums.outandaboutlive.co.uk/forums/Motorhomes/Motorhome-Matters/Huge-tax-increase-for-new-motorhomes-/52889/61/

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As I’ve said elsewhere, DVLA Form 355/1 (Notes About Taxation Classes) used to state that all three classes (Petrol Car, Diesel Car and Alternative Fuel Car) that make up the graduated VED group were restricted to M1* passenger vehicles with a gross weight not exceeding 3500kg.

 

However, it will be apparent from this current (October 2019) version of DVLA Form 355/1 that the definitions of the Petrol Car, Diesel Car and Alternative Fuel Car classes now contain no reference to a 3500kg threshold.

 

https://tinyurl.com/y63quyel

 

This link is to a February 2017 NCC/DVLA document providing vehicle-tax guidance for motorhome dealers.

 

https://tinyurl.com/wscfv4s

 

The flow-chart on Page 2 asks the question "Does the motorhome have a CO2 figure on the final stage Type Approval? (i.e. CoC* or IAC*)” and, if the answer is YES, the motorhome will be taxed based on its CO2 figure and price. The motorhome’s weight is ignored if there is a CO2 figure and is only taken into account if the answer to the question is NO, when the motorhome will be assigned to the PHG or PLG class according to the weight recorded in the motorhome’s documentation.

 

Removal of the 3500kg threshold from the graduated VED classes was always on the cards. The 3500kg maximum didn’t matter much when almost all new motorhomes had no CO2 figure on their final stage Type Approval certificate of conformity (CoC), but, if all/most motorhomes’ final stage CoC began to carry a CO2 figure, VED taxation would become a nightmare for the DVLA if the 3500kg threshold were left in place. It’s easy to predict the inevitable VED complications that motorhome weight uprating/downrating would produce, never mind trying to justify an irrational scenario where the VED charge for a new small light motorhome costing £45k would be massive, but the VED charge for a new huge heavy motorhome costing £145k would be a relative pittance.

 

While the CO2 and price-based VED system beginning to apply generally to new motorhomes obviously won’t be popular with UK motorcaravanners considering buying a new motorhome (nor with the UK motorhome trade) a VED structure based on CO2-emissions + price is a lot more logical than the historic weight-based system where the VED charge for heavy motorhomes was significantly less than for light ones.

 

The National Caravan Council (NCC) has provided information about the DVLA’s stance after 1 September 2019 and this guidance has been published on-line on several motorhome dealership websites. The following link is to the relevant Brownhills webpage

 

https://www.brownhills.co.uk/beat-the-vehicle-registration-and-taxation-increase.html

 

I’m assuming that Euro 6 d/2 engines are the same as Euro 6d-TEMP engines, but Question 3 and its answer are clear enough

 

3. Will the higher duty apply to large motorhomes in excess of 3,500 kgs?

Yes, if a Euro 6d/2 specification engine is installed.

 

More NCC material about motorhome VED is available in the downloads on this link

 

http://www.fairmotorhometax.org/downloads

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In my last posting I said "I’m assuming that Euro 6 d/2 engines are the same as Euro 6d-TEMP engines”, but that may well not be the case.

 

This May 2019 Fleet Industry News article

 

https://www.fleetnews.co.uk/news/fleet-industry-news/2019/05/01/rde2-compliant-cars-help-diesel-to-hit-back

 

refers to the Real Driving Emissions (RDE) test and says

 

Under the RDE test, the car is fitted with a portable emission measuring system (PEMS) before being driven for 90 minutes on public roads in different conditions, with both uphill and downhill driving, and a mix of urban and rural roads and motorways.

 

It is being introduced in two stages, the step 1 test – RDE1 – became compulsory for all new type approvals from September 1, 2017, when WLTP was also introduced.

 

RDE1 will become mandatory for all new registrations from September 1.

 

WLTP testing, which takes place in the lab, has been mandatory for all new registrations since September 2018, with diesel cars having to meet the NOx limit of 80mg/km and petrol 60mg/km, with cars achieving the limit labelled Euro 6c.

 

New type approvals, however, have also had to meet the limits on-the-road from September 2017.

 

The EU has cut manufacturers some initial slack, allowing for a margin of error two times the actual limit. Cars achieving RDE1 are classified as Euro 6d-temp.

 

However, the rules will begin tightening from January 2020, starting with new type approvals.

 

This next stage, RDE step two (RDE2), is the measure now being achieved early by some manufacturers, giving fleets and company car drivers the benefit of a tax cut first announced in Budget 2017.

 

The NOx limit for the RDE2 standard is up to 1.43 times the Euro 6 lab limit of 80mg/km for diesel and 60mg/km for petrol. Cars achieving this limit are labelled Euro 6d.

 

RDE2 will apply to all new registrations from January 1, 2021, before the margin for error – the conformity factor – will be removed by 2023.

 

The DVLA’s current Form V149 (rates of vehicle tax effective from 1 April 2019)

 

https://tinyurl.com/y4aunfof

 

has - for cars registered on or after 1 April 2019 - two ‘first licence’ rates of tax for diesel cars, one for cars tested to RDE1 standards and the other for cars tested to RDE2 standards.

 

So, the “Euro 6d/2 specification engines” referred to in the NCC guidance are more likely to be Euro 6d RDE2 motors than Euro 6d-TEMP motors.

 

I’m pretty sure that what Andrew Bromley was told chassis-weight-wise is twaddle and, if a motorhome is going to be assigned to a graduated emissions VED class, the vehicle’s gross weight (real or ‘potential’) and chassis specification (FWD, RWD or 4x4) will not be relevant. However, it’s evident from DVLA Form V149 (that is already in force) that, before the appropriate VED charge(s) could be calculated, which RDE standard the motorhome’s engine complies with must be known.

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I must admit to getting slightly lost amongst all the possible scenarios, but I am beginning to wonder if the van tested was on a older (not necessarily very older) chassis and the person giving van for testing didn't appreciate quite why the tax bracket was at the lower rate. This might lead to vans being ordered under the impression that they would be at the lower rate, but when they come being hit with higher rates. When I've ordered new vehicles the 'on the road price' always contains a note that any higher VED or tax is beyond control of vendor and will have to be paid.
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Peter Vaughan’s VED-related comment in MMM magazine may be correct, but not because the Dethleffs Globeline model is RWD nor the gross weight of the vehicle on test being 4100kg. What Andrew Bromley has been told about there being a 3500kg threshold applying to the graduated VED classes is also wrong.

 

In early 2016 I highlighted that DVLA Form V355/1 indicated that the CO2-emissions-based graduated VED classes applied only to pasenger-carrying vehicles in the M1* category with a ‘revenue weight’ (ie. gross weight) not exceeding 3500kg, and that the DVLA had confirmed this was so when I contacted them.

 

This ukmotorhomes.net webpage discusses motorhome VED

 

https://www.ukmotorhomes.net/motorhome-faqs/motorhome-road-tax

 

and it will be seen that - in the section headed VED RULES FROM 1st APRIL 2017 - a 3500kg gross-weight maximum is mentioned as one of the three criteria that needed to be met for a motorhome to be assigned to the graduated VED classes.

 

I’m doubtful that, in 2017, a 3500kg threshold was still included in the definitions of the graduated VED classes (archived versions of Form V355/1 are not available on-line) as there is no mention of a 3500kg limit in this NCC/DVLA document with a February 2017 issue-date, neither within the flow-chart nor in the text.

 

https://tinyurl.com/wscfv4s

 

I really don’t know how the DVLA are going to play this. If I were the DVLA I’d keep it simple and continue with what was advised to motorhome dealers in the February 2017 NCC/DVLA documen If a new motorhome’s final-stage CoC has a CO2 figure on it, I’d just assign the vehicle to the graduated VED classes and not make RDE or RDE2 compliancy an (apparently) critical factor.

 

As the current Form V149 lists different VED rates according to whether a new car’s motor is tested to the RDE or RDE2 standard, it must be possible to establish from infomation relating to a car whether its motor is RDE or RDE2 compliant. And if it’s possible for cars, it should be possible for motorhomes too.

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Colin.

 

I think things are being much over-complicated.

 

The great majority of base vehicles for conversion are homologated against the Euro n (Arabic numbers) standards applicable to cars and light commercial vehicles. The legislation for these standards requires Euro 6d(temp) for new registrations from September this year, (with a derogation allowing those non-compliant vehicles already "in the system" to be registered for some time yet).

 

Part of these standards dictate that, in parallel with the Euro 6d(temp) requirement, multi-stage vehicles (such as motorhomes) must now assess and show a final-stage CO2 emissions figure on the (final stage) COC.

 

As, pre-dating this requirement, UK taxation rules dictate that the presence of such a final-stage CO2 figure requires taxation in a graduated emissions class of tax, rather than the previous PLG/PHG classification, then all motorhomes built on a chassis homologated against these Euro n (Arabic numerals) car and light commercial standards will now be subject to such graduated tax, and can't escape it (regardless of weight)..

 

Ducatos (and similar), FWD Sprinters, and (AFAIK) Renault Masters are all homologated against this standard, and new vehicles are currently designated Euro 6d(temp).

 

However (and referencing posts from both myself and Derek above), subject to certain criteria a particular base vehicle may (by choice of the manufacturer and customer) be homologated against entirely different standards, those for "Heavy Duty" vehicles. These standards carry a confusingly similar classification, Euro xx (but Roman, not Arabic numerals). The standards and rules for these are entirely different to those for the passenger car/light commercial vehicle category, and appear to me to be lagging and somewhat less stringent. Critically, they do not appear to fall foul of the recent requirement to assess and state a final-stage CoC CO2 rating, which means that, at least currently (I suspect things will change) it is entirely possible and legal to avoid graduated VED with a motorhome conversion on the same, and one would assume that PHG/PLG rating will apply.

 

The RWD sprinter chassis cab is patently (MB data) homolgated against these different "Heavy Duty" standards under certain circumstances, and the vehicle is currently stated as being available in both EuroVI and Euro6 versions (customer choice subject to meeting appropriate criteria).

 

So, the 'van in question has been built on a Sprinter base which has been homologated against the "Heavy Duty" standards, which therefore does not have to state emissions data on the final-stage CoC, and is thus not subject to emissions-graduated VED.

 

I would suspect that the loophole will be closed sometime (perhaps at the next update of the "Heavy Duty" standards), but it is extant, and thus does not involve an elderly base vehicle.

 

The nub of the argument is that EuroVI and Euro6 are very different, cover different standards, for different vehicles, but there is an overlap somewhere in the middle which would allow a base vehicle to be assessed against either, and this is what has happened here.

 

(I can find some reference to the ability to specify "Heavy Duty" for FWD Sprinters, but I can find no way of configuring that option. On the RWD version, either type of homologation is an option on the lighter versions, but only "Heavy Duty" on the heavier ones).

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Agree with your facts, but the truth is : I would have by now replaced my 6 year old Euro5 powered Motorhome, and probably my 10 year old car also (car tax £30 per annum) but because of 'Luxury car' tax and punitive annual taxation I will keep my more polluting vehicles going for as long as possible.

Surely financial encouragement and help into more modern vehicles would help the environment better and keep motorhome production moving. I fear for the smaller van converters who must be being hit badly by these tax increases. And by defination ARE increases on what were previous non- Coc rates.

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Robinhood - 2019-12-26 5:36 PM

 

...I think things are being much over-complicated...

 

 

This thread has concentrated on a throw-away comment by Peter Vaughan in his review of a Dethleffs Globeline motorhome, but let’s put that aside for now and examine the bigger picture.

 

DVLA Forms V149 and V149/1 cover UK vehicle tax rates that will be in force until March 31 2020, with Form V149 providing details of the charges relating to the graduated VED categories, and (as I said earlier) diesel cars in the graduated VED categories are currently taxed according to whether they meet RDE or RDE2 standards, with the charges for RDE-standards cars being the higher.

 

The prevous year’s Form V149 provides a little more detail about the two RDE standards, saying

 

* Diesel cars tested to RDE2 standards with NOx 80mg/km or less.

** Diesel cars tested to RDE standards or RDE2 standards with NOx greater than 80mg/km

 

and this September 2019 article provides RDE-related information.

 

https://www.fleetalliance.co.uk/news/tax-beating-rde2-diesels-are-on-the-rise/

 

The National Caravan Council has a website dedicated to motorhome road tax

 

http://www.fairmotorhometax.org/

 

and, thoughout that website, the term WLTP Euro 6d/2 is repeatedly used. However, the NCC website does not define what the term means technically, and the following Question and Answer advice

 

4. How do I know if my new motorhome has a Euro 6 d/2 engine?

Your dealership will be able to explain. Initially, most new motorhomes will still carry the Euro 6 b/1 engine which is not affected by the new rules and will be taxed at the current rate.

 

may amuse but is hardly explanatory.

 

The Euro standard to which “Euro 6 d/2” relates may be pivotal to whether a new motorhome is assigned to the graduated VED categories or, if it is, what the VED charges will be.

 

My understanding (which could easily be wrong) is that the correct ‘Euro’ description for cars compliant with the less stringent RDE testing regimen is “Euro 6d-TEMP” and, are for cars compliant with the more stringent RDE2 regimen the correct description is “Euro 6d”.

 

I’ve looked at a number of on-line 2020 motorhome technical specification documents and (as far as I can see) all models that are Fiat Ducato-based are described as having a Euro 6d-TEMP motor.

 

This is the case for the Ducato-based models described in the 2020 Dethleffs document, HOWEVER, the motor of the Mercedes Sprinter-based Globeline model is stated as being “Euro VI D”, as is the motor of the Iveco Daily-based Alpa A 9820-2 model.

 

If, between now and next April, a new motorhome to be UK-registered has a CO2 figure on its Certificate of Conformity (CoC), how should one expect the DVLA to treat it VED-wise?

 

If the NCC’s “Euro 6d/2” term is synonymous wih “Euro 6d-TEMP”, then the motorhome should be assigned to the graduated VED classes (which apparently means all Ducato-based motorhomes would be so assigned). But, if the NCC’s “Euro 6d/2” term means “Euro 6d”, very few motorhomes’ engines currently meet that standard and (presumably), as a consequence, few motorhomes would be assigned to the graduated VED classes (at least in the short term).

 

And, whatever “Euro 6d/2” actually means, if a motorhome’s engine complies with a non "Euro 6” standard (as the Dethleffs Globeline and Alpa models’ engines do, being to a Euro VI standard) the vehicle should end up according to its gross weight in either the PLG or PHGV VED class.

 

This is a real nest of worms and, if the (understandable) intention was to produce a level playing-field where any new motorhome with a CO2 figure on its final-stage CoC would be UK-registered according to its engine’s ‘greenness’, and the procedure for doing this would be straightforward and comprehensible, that intention has certainly not been achieved.

 

(What is needed is not the NCC blathering on, but the DVLA stating categorically and in detail what is going to happen.)

 

 

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The complexity of the UK motorhome VED issue really becomes evident when 2020 Carthago documentation is examined.

 

For the 2020 model-year Carthago will offer motorhomes based on three base-vehicle makes.

 

1: Fiat Ducato - front-wheel drive, single or tandem rear axle arrangement, Euro 6d-TEMP powerplant.

 

2: Mercedes-Benz Sprinter - front-wheel drive, single or tandem rear axle arrangement, Euro 6c powerplant.

 

3: Iveco Daily - rear-wheel drive, single 'twinned-wheel’ rear axle arrangement, Euro VI d powerplant.

 

In some instances essentially the same conversion is offered on different makes of chassis - for example “Liner-for-two” models are available on a Fiat Ducato or Iveco Daily base. So, if the DVLA plans to assign to the graduated VED classes only motorhomes that have a Euro 6d-TEMP engine, a Fiat-based Liner-for-two will end up there, but a look-alike Iveco-based Liner-for-two will be placed in the prehistoric PHGV VED class.

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I notice that the January 2020 issue of the Caravan and Motorhome Club (C&MC) magazine includes an article (Page 70) about the ‘new’ motorhome VED regulations.

 

The article refers to vehicles with “new Euro 6d/2 grade engines” and to “older Euro 6b/1 engines” but I can’t find any mention of those specific ‘Euro 6’ designators being used other than in the NCC (and now C&MC) literature.

 

However, the C&MC magazine article does say

 

“...some of the largest (motorhomes) may have a Euro VI (heavy duty) engine classification which still commands a low tax rate (note this doesn’t simply mean vehicles over 3,500kg)."

 

Later in the magazine (Pages 80-82) is an article reviewing a Benimar Tessoro 483 motorhome built on a 3500kg Ford Transit front-wheel-drive chassis. In the TECHNICAL section of the review, the vehicle’s engine is described as “2-litre turbodiesel Euro VI”, but I’m pretty sure this is incorrect.

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Euro 6b and Euro 6.1 (and likewise Euro 6d and Euro 6.2) seem to be used almost interchangably to mean the same thing, I suspect Euro 6b/1 and 6d/2 is simply hedging one's bets.

 

The current UK Transit brochure does indeed show a (very) limited availability of Euro VI engines (the vast majority are Euro 6.2). It doesn't look like there is availability on the FWD chassis cab, but who knows what can be supplied elsewhere in Europe (or at bulk customer request).

 

And subsequently added, from the current Transit brochure:

 

Heavy Duty Stage 6 diesel engines

To comply with the latest emissions regulations, any regular production or converted vehicle with a reference mass of 2,840 kg† or over (except motorhomes, ambulances and hearses), must meet HDT requirements. Therefore, Transit Chassis Cab is available with a 130 PS or 170 PS Heavy Duty diesel engine, in addition to the Light Duty powertrains.

 

(This is exactly the same "loophole" as being discussed for the Sprinter, and I would interpret the comment about motorhomes as meaning it isn't mandatory under those circumstances, but is still possible).

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Yes, but does Euro 6d/2 refer to Euro 6d-TEMP or to the more stringent Euro 6d standard?

 

If (when) motorhomes start turning up in the UK with a CO2 figure on their final-stage CoC, for UK-registration purposes the logical next step would be to confirm what Euro 6 classification the vehicle’s engine has and this should be apparent from the motorhome’s CoC (the Fiat and Rapido CoCs both indicate that my motorhome has a Euro 5 engine).

 

But if the NCC is using ‘non standard’ Euro designators that won’t appear on the CoC, how can it be known which VED class a motorhome can be expected to end up in?

 

I’ve no great problem with a new motorhome with a CoC CO2 figure and an engine with a Euro designator that is not ‘6d type’ (eg Euro IV or Euro 6b) being assigned to the PLG or PHGV VED classes (though I think this would be even less rational than the old weight-related system) but it would be nice for everbody’s sake if the DVLA would state EXACTLY how it plans to treat motorhomes that have a CO2 figure on their final-stage CoC.

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  • 2 weeks later...

BBC1 'Look North' (East Yorkshire & Lincolnshire) available in iplayer till 7pm tonight, covered the redundancies at Swift caused by the taxation change for new motorhomes. A bit of the factory shown. Then showed the local (Labour) MP asking question in the House of Commons, Tory Minister said they'd look into it

*-)

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The consultation with staff commenced last November and was quoted at the time as a necessity to reduce its production of touring caravans, so whilst taxation changes on motorhomes may now be having an effect, wider issues including people's reluctance to spend on big ticket items in the current economic climate of uncertainty are likely to be just as big, if not a bigger part of the picture.

 

The motor industry as a whole is also suffering declines in vehicle sales, and although subject to the same excise duty regime as now affects new motorhome registrations, the tax on all but the most expensive or polluting cars has not been subject to increases other than in line with inflation.

 

My 2017 Volvo is substantially cheaper to tax than my previous 2002 Ford, both with engines of similar power and capacity.

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The tax was presented as an incentive to choose a less polluting car.

(Fair Enough - people who buy a 140mph car to travel on 70mph roads should pay extra for their unnecessary pollution.)

But the point here is that Motorhome buyer doesn't have that choice.

(And the high tax takes no account of the average Motorhomes low mileage.)

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John52 - 2020-01-08 10:16 AM

 

The tax was presented as an incentive to choose a less polluting car.

(Fair Enough - people who buy a 140mph car to travel on 70mph roads should pay extra for their unnecessary pollution.)

But the point here is that Motorhome buyer doesn't have that choice.

(And the high tax takes no account of the average Motorhomes low mileage.)

 

I'm not arguing with any of that, just pointing out that Swifts original consultation on its restructuring proposals blamed falling sales of touring caravans which are not subject to VED, and that new car sales have also been falling across the board, despite VED for many of those vehicles being lower than that imposed on broadly equivalent older models.

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Derek Uzzell - 2020-01-08 11:40 AM

 

This link may be of interest

 

https://www.jerbacampervans.co.uk/new-road-tax-ved-for-campervans-motorhomes/

 

I'm not sure about it's accuracy, but the suggestion is that any motorhome UK-registered prior to April 2020 will be taxed according to the 'old' regimen.

 

It is entirely consistent with the HM Treasury briefing document on WLTP which I mentioned here last August, which stated that new WLTP CO2 figures although appearing on new CoCs of affected vehicles from 1st September 2019, should not be used to determine vehicle tax rates until April 2020 at the earliest.

 

This link also contains relevant information.

 

https://www.gov.uk/government/publications/rules-to-measure-carbon-dioxide-emissions-for-vehicle-excise-duty

 

 

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I'm still uncertain how motorhomes are going to be treated by the DVLA for VED purposes.

 

When this document was published in 2017

 

https://tinyurl.com/wscfv4s

 

the flow-chart seemed clear enough, as did the guidance. Basically, if a motorhome's final-stage CoC had a CO2 value on it, the vehicle would be assigned to the 'car' graduated VED classes.

 

But there are now two different VED 'rates' for diesel-fuelled cars and it would appear that the DVLA will only be assigning to the graduated VED classes motorhomes that have a specific Euro emissions standard, not just any motorhome that has a CO2 value on its CoC.

 

This would mean that motorhomes having a CoC with a CO2 value on it, but with a motor conforming to a different Euro standard (eg. Euro VI not Euro 6) to that chosen by the DVLA would be assigned to the PLG or PHGV VED class according to the motorhome's weight. And if that happens, it would probably be large heavy expensive motorhomes with high CO2 emissions motors that would end up in the (bargain price) PHGV class, and surely that's exactly the opposite of what a 'green' VED policy for motorhomes should be seeking to achieve?

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I doubt that there is any intention to create an anomaly favouring less "green" vehicles. In my view, it is just that legislation has become so complex that when creating additional regulations and Acts of Parliament, there are often unintended effects or omissions which take time to be recognised and corrected or are sometimes just left in the too difficult box.

 

When I worked in that field, many of us were of the view that legislation was deliberately created that way to keep the legal profession gainfully employed ;-)

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Deneb - 2020-01-09 4:26 PM

 

When I worked in that field, many of us were of the view that legislation was deliberately created that way to keep the legal profession gainfully employed ;-)

 

That is exactly how so much of life is now managed. It matters not what the cost is, people must be employed, it even overflows into the climate and clean air challenges, and wasn't it Dr Goebbels who used a similar tactic.

 

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