Insuring an Import , other side of the channel

[fjmike]

Hi received news today that even though the new EU directive will be in force by the end of June, my insurance company(Safeguard) will not cover for the other side of the channel. This leaves us in a bit of a mess as France has already taken up the directive so(french insurance companies) cannot insure an export. Anyone know of a company that has their finger on the pulse a little more and would issue cover.

[Brian Kirby]

I think you may have to shop around for this, it's never going to be mainstream insurance - too few of us do it.  You could try Caravan Club, Camping and Caravanning Club and, since they specialise in motorhome insurance, Comfort.

Please let us know how you get on.

[Hughmer]

I brought one in from Germany a few weeks ago. Caravan Club could not cover. Didn't try C&CC. But I did try nearly every other likely suspect.

 

MotorcaravanWise were the only ones able to help. Offered 14 day cover on a VIN. I think there was a 10% discount for membership of Caravan Club.

 

Speak to Anita. 01425 280078

 

Happy camping

 

 

 

 

[Mel E]

I have checked with several insurance companies as well as the MIB and ABI. None were even aware of the Fifth Directive. All promised to get back to me (in my role as a freelance writer) but none have done so.

 

It looks very much as though we will have to wait until UK implementation (which must happen by 10 June) to see what they decide to do.

 

If my reading of the regulations is correct (and I'm pretty sure it is!), then all that will be neccessary is to get fully comp cover on the vehicles VIN number and you will automatically be covered abroad for the importation. However, insurers can make life difficult by simply refusing you any cover at all.

 

We shall see.

 

Mel E

====

[Derek Uzzell]

In July 2005 Devitt Insurance Services Ltd (the Caravan Club's insurance broker) arranged a 'comprehensive' policy for me with NIG. This was to cover my importing a motorhome from Germany and was to be operative from the point of sale.

 

At the time I was somewhat doubtful of this policy's legality and tried, at a later date, to pin down Devitt over exactly what I had been sold. I found this frustratingly difficult to do and, despite being assured in writing that "the covernote issued to you covered you against all risks from point of sale until your return to the UK", I never really believed this.

 

When this subject subsequently arose on this forum and it was claimed that MotorcaravanWise could arrange similar 'comprehensive' policies for motorhomes being imported I contacted that company. It seemed to me then that MotorcaravanWise were uninformed about the rules regarding being unable to provide 3rd Party cover abroad and were issuing ordinary cover-notes exactly as Devitt had done. MotorcaravanWise promised to look into the matter and ring me back - unsurprisingly they never did.

 

I mention this purely as a heads-up to prospective importers.

 

 

[Brian Kirby]

As a rider to Mel's comment above: from what I have read of the Directive, it seems it should also be possible to obtain cover against a temporary registration number issued in the exporting country.  For some, this may offer an easier way to identify the vehicle than obtaining the VIN. 

However, as Mel says above, it seems we shall just have to wait until after 10 June to see how insurers react to the new rules, and what sort of fuss they then make about changing the details of the insured vehicle after its UK registration.  We're close, but we ain't quite there yet!

[Mel E]

Just so that everyone is completely clear about the change, here is the relevant explanatory paragraph in the Fifth Directive (all directives have these explanations first, followed by the much more complex list of amendments and additions to the law that put them into effect in EU Law):

 

Steps should be taken to make it easier to obtain insurance

cover for vehicles imported from one Member State into

another, even though the vehicle is not yet registered in the

Member State of destination. A temporary derogation from

the general rule determining the Member State where the

risk is situated should be made available. For a period of

30 days from the date when the vehicle is delivered, made

available or dispatched to the purchaser, the Member State

of destination should be considered to be the Member State

where the risk is situated.

 

That seems clear enough to me!

 

Mel E

====

[Derek Uzzell]

From what I recall of my importing experience, there was no problem obtaining the motorhome's VIN from the German dealer in sufficient time for Devitt to post me a cover-note and for me to receive it before I set off to collect the vehicle. At that point, of course, the motorhome had no registration number, and I'm pretty sure the cover-note carried "CHA551S" in the appropriate field (presumably to comply with Devitt's computer system requirements that something that resembled a legitimate UK reg. no. be present there).

 

I'm a bit doubtful that the German registration system would permit a temporary registration number to be assigned to a 'virtual' vehicle as, when my Hobby was going through the registration process, someone physically checked that the motorhome's VIN matched the documentation being presented, and it was only after that check had been made that the temporary registration number was assigned. What I'm getting at is that, with the German system, it seems far more likely that one can learn the VIN well before one can identify the temporary registration number.

 

Once my motorhome had been UK-registered, I had no difficulty whatsoever replacing the cover-note with a proper insurance certificate. I just advised Devitt of the vehicle's UK registration number and returned the cover-note to them.

 

As far as I can see, if, after June 10, UK insurance brokers/companies that are willing to offer cover abroad follow the procedure that Devitt and (I'm assuming) MotorcaravanWise have used in the past - issue a VIN-based cover-note that's later converted to a UK registration number-based policy - things should be straightforward.

[Mike Chapman]

Maybe I have misunderstood the reasoning behind the above postings but the question that keeps going through my mind is how do the manufacturers and dealers or the specialised transport (sometimes very small one vehicle operations) companies insure the vehicles they are importing/exporting?

 

If they can get cover surely the same insurance companies as they use should be able to provide cover.

 

Has anyone consulted the breakdown companies such as AA, RAC, Greenflag or Mondial about how they insure for recovery of UK customers vehicles from other European Countries.

 

Is this too simple?

 

Regards,

 

Mike.

[Brian Kirby]

Mike

The first group, if they bring the vehicles in on transporters, insure them as goods or, if driving them to UK, bring them in on trade plates with trader's insurances, not available to the public.

The second group are recovering, usually on low loaders, vehicles already registered in UK.  In most cases, the vehicle's insurance will be irrelevent, because it won't be on the road.

[Mike Chapman]

Hello Brian,

 

Thanks for the reply and the explanation, good points.

 

To answer Fjmike's original posting on this issue has anyone actually tried the Trade Insurers to see if they will provide cover for importing by a non-trade individual customer? Surely the same problem relates to other vehicles such as cars. I distinctly remember that Mercedes arranged insurance for vehicles being collected by customers from their German factory so perhaps the overseas Manufacturers could assist.

 

Regards,

 

Mike.

 

 

[Brian Kirby]

Can't answer for Mercedes, Mike, but most non-UK ( and I suspect most UK) motorhome manufacturers rather resent the idea that some of us pop over to Europe and buy vans at European prices. 

One German manufacturer claims to directly sell their vans to UK dealerships at exactly the same price as they are sold in Europe, subject only to a surcharge of around 400 Euros on the rhd chassis, but even their vans sell in UK for several thousand pounds more than they are currently for sale in Germany.

The rest just climb on the bandwaggon, and charge us what our market will stand - which seems to be at least £4,000-5,000 more than the european for even the cheapest vans; rising on more expensive vans. 

Why?  Presumably, because they can.  As with cars, we have been educated to believe motorhomes (generally) cost from £30,000 up, whereas the rest of Europe knows they cost from £25,000 up!  The difference, as was the case with with cars, is largely created by our own manufacturers. 

Interesting, isn't it, how much car prices have dropped in the UK since we ceased volume car making.  I know we still make a lot of vehicles, but not via homegrown makers.  Be interesting to see what happened to motorhome prices if UK manufacturers all put up the shutters.  Personally, I rather suspect they'd follow car prices downwards.

However, given that the UK market affords foreign manufacturers such enhanced profits, what makes you think they have the slightest interest in helping us to buy for less?  Do turkeys vote for Christmas?

[Derek Uzzell]

It used to be commonplace for professional motorhome importers to send people abroad to ferry-drive new Continental-built vehicles back into the UK. This practice came to a shuddering halt when the DVLA introduced regulations insisting that a brand new imported vehicle that had been driven to the UK needed to be registered quickly (normally within 14 days of collection) to be counted as 'new' for UK registration purposes. Faced with the prospect of finding a buyer for the imported motorhomes within 14 days or having to register the vehicles in their own companies' names (and thus making the motorhomes 'second-hand'), importers/dealers opted instead to have the vehicles transported to the UK thus circumventing the DVLA rule.

 

I'm aware of just one professional UK company that continues to drive new imported motorhomes to this country, but this firm essentially provides a middle-man importing service on behalf of its UK clients (rather than operating as an importer or dealership). In this instance, as each new imported motorhome will already have a UK buyer avid to get his/her hands on it as soon as it reaches these shores, the DVLA 14-day limit loses importance.

 

Preparatory to importing a new motorhome from Germany myself, I did discuss insurance/registration matters with a UK dealer acquaintance who I knew fetched (or delegated an employee to fetch) the occasional motorhome from abroad, either for his own use or to pass on to a customer and with the vehicles being driven back to the UK on trade-plates. The idea of me 'borrowing' a set of trade-plates was mooted, but I was uncomfortable with the legality of this ploy. When I asked whether the dealer was certain that his own traders' insurance actually covered the importing method he was employing, he said he hadn't checked with his insurer, had assumed it would, but, now that I'd mentioned the 'UK insurers can't provide 3rd Party cover' problem wasn't so sure.

 

Frankly, if one accepts that it has been legally impossible for any UK insurer to provide 3rd Party cover for a non-UK-registered vehicle while it is being driven abroad, this casts considerable doubt on the wisdom/validity of importing motorhomes via traders' insurance.

[fjmike]

I don't want to seem ungrateful for the replies so far but with the implimentation of the European 5th Directive this info will become erelevant. I have phoned round a few motorhome insurers and apart from a few that said they would find out and get back to me after the B/Holiday have not had any success. One bit of info though the woman from CaravanGuard said that they would not cover a self import at all. Her flawed (to me) arguement was that a person who has bought abroad would have purchased at a far lower price than UK but would expect in the event of an accident to be paid out the full UK price. I said her arguement was flawed as said person could obtain an really good discount on a UK purchased van, yet they would have no problems with insurance cover???????????

[Mike Chapman]

Derek Uzzell - 2007-05-28 8:31 AM

 

 

 

Frankly, if one accepts that it has been legally impossible for any UK insurer to provide 3rd Party cover for a non-UK-registered vehicle while it is being driven abroad, this casts considerable doubt on the wisdom/validity of importing motorhomes via traders' insurance.

 

Hello Derek,

 

So the answer then seems to be wait until the Insurers get their act in order, if ever and that all those who have purchased or until then will purchase their new vans abroad and drive them home have been/will be uninsured to do so? There must be an answer to this, I cannot believe that there is not one insurance company out there that will not/cannot provide cover or is it purely a question of the cost?

 

Regards,

 

Mike.

[John Keats]

Maybe this isn't possible but I've long since wondered why the british public cannot buy vehicle insurance from any EU country and in particular if the vehicle is purchased in the EU, it must surely come about at some time.

 

Many other industries are EU owned to whom we pay for their services, why not Insurance and in particular since many vehicles driven in the UK are not made here anyway.

 

Or is just that no insurer has made the approach yet ?

 

I'm also sure that many vehicle owners cover as many miles on the continent as they do in the UK.

 

Last year in our M/H driving in France amounted to more than the UK.

[Brian Kirby]

Back to Mike's question: since you've previously said the van won't be ready for collection untill 29 June, there seem to be three possibilities. 

First: wait until after the directive comes into force.  This doesn't seem such a cliff hanger as it may appear at first sight.  You'll need to know at least the VIN to be able to get insurance, and the dealer is unlikely to be able to confirm that before the van is delivered to him.  Since all deliveries seem to have been delayed by chassis supply problems this year, it wouldn't be entirely surprising if your van turns up late.  (Don't count on advance warning from the French dealer, he may let you know, but voluntary communication doesn't seem to be part of the French character, much as I love them!)  Anyhow, back to the point: after the directive is in force, ring round the insurers again, and make a point of checking Comfort, who I think will be up to speed.  What Mel says above - in effect that once the directive comes into force, insurance on an imported van's VIN will automatically cover it outside UK - just seems so logical.  It is simple, requires no special recognition, and merely extends the scope of cover.  (Sorry for the length of this bit!)

2 Obtain French third party only insurance and drive carefully home on that!  This should not really become be necessary.

3 If necessary, be prepared to delay collection for a few days until the UK insurers get their act together.  However, you can start asking on 11 June, so you'll have the thick end of three weeks to get it sorted, more if there are delivery delays with the van.

The uncertainty is unsettling and frustrating, but I suspect it will all resolve along the lines Mel indicates.

If you really can't stand the strain in the meantime, phone Comfort and see if you can get through to Ben, or Peter, Cue.  I suspect they'll be able to tell you where things stand at present, where they expect them to go, and whether they anticipate providing this cover themselves post 10 June.  However, they may well not yet know the actual rates, so may not yet be able to take on the business.

[fjmike]

Thanks for that in depth reply Brian. To clarify some points (this is probably me not explaining proper). 1 the van is at the dealers , we have seen it and have asked for speedo etc to be changed.

2. If I have read the new EU directive properly getting insurance from a French insurer is out as the directive prohits this, it has to be insured with the country that it is going too.

Anyone have any spare finger nails as both me and her indoors have bitten through ours

[Derek Uzzell]

Mike Chapman:

 

I'll start by re-capping on the insurance conundrum that has faced private motorhome importers in recent years when they plan to drive the vehicle back to the UK from the point-of-sale in Continental Europe.

 

1. It has been possible to obtain 'area-restricted' comprehensive cover based on the imported motorhome's VIN from several UK insurers. (By "comprehensive" I mean 3rd Party cover, plus vehicle-related cover against fire, theft and accident-damage risks.) HOWEVER, this cover operates only when the motorhome reaches UK shores and is being driven within the UK.

 

2. I'm not certain what happens in other EC countries, but, in Germany, basic 3rd Party cover can be purchased for a specified duration when the motorhome is being temporarily registered. This insurance cover is valid throughout the EC and will permit the importer to drive his/her motorhome legally during the journey home.

 

3. Where there have been problems obtaining insurance abroad, or where the importer has attempted to avoid purchasing insurance there, various ploys have been used. For example, the Continental dealership agrees to deliver the motorhome to the ferry-port/Channel Tunnel and the buyer takes over at that point. Logically, this will leave the buyer and vehicle uninsured from the moment he/she takes control of the vehicle until the ferry/train reaches the UK. "JudgeMental" has mentioned driving his recently imported motorhome abroad under the protective umbrella of the vending dealer's insurance and trade-plates. This may be legally OK but, personally, I've got a gut-feeling it isn't.

 

What private motorhome importers have continually sought is a simple arrangement that provides full 'comprehensive' insurance cover from the moment the vehicle has been handed over to them abroad. And, every now and again, an importer has (apparently) been able to obtain such cover from a UK insurer. I obtained it from the Caravan Club's broker and, earlier in this thread, I think "Hughmer" is saying that MotorcaravanWise provided it to him.

 

Now, received wisdom is that UK insurers can't legally provide 3rd Party cover for a non-UK-registered vehicle while that vehicle is outside the UK. Theoretically, UK insurers could provide vehicle-related cover (fire, theft, accident damage) but, to do so, they would have to custom-write a policy that provided 'genuine' comprehensive cover once the motorhome had arrived in the UK but excluded the 3rd Party component while the motorhome was on the heading-towards-the-UK leg of the trip. Clearly, given the tiny number of people privately importing motorhomes from abroad, doing this is not something considered to be commercially worthwhile.

 

As I said earlier, the CC's broker issued me with a standard 'all risks' cover-note (ie. with no amendments on it saying that the 3rd Party component was inoperative while the motorhome was outside the UK) and I believe that MotorcaravanWise does the same. I've discussed this practice with various other brokers (and at length with Mel Eastburn) and, as a result, concluded that it invalidates the cover being offered.

 

People like to believe what they want to hear. It may be a pleasant surprise to find that an insurance broker (like Devitt or MotorcaravanWise) can offer exactly the cover you've been looking for when every other broker contacted has said No. But what you really need to ask yourself is why, in an intensely competitive environment like the insurance business, the provider claiming to be able to arrange the cover is unique. Has the provider identified a magic legal loop-hole (unlikely!) or is the provider just clueless (Hmmm!)?

 

It also needs saying that you don't necessarily HAVE to put yourself into harm's way insurance-wise. Although it may be convenient (and the cheap option) to fetch your heavily price-discounted motorhome from abroad and drive it home, you could consider using a transport company to bring the vehicle to this country and collect it from the UK point-of-entry yourself. I know one UK motorhome dealer has employed this method in the past and, when I was researching German dealership from which I might buy my Hobby, the option of using a transport company was mentioned.

[Brian Kirby]

I have been given an update to the above from my insurers, which suggests great caution is still needed before proceeding with any personal import for the time being.

There are continuing technical difficulties in harmonising pan-European insurance procedures, that will have the effect of delaying practical implementation of DIRECTIVE 2005/14/EC for some time after 11 June 2007.

This means that the status quo will continue to be the case: that is to say that temporary insurances on vehicle chassis numbers can continue to be issued by UK insurers, but these will only have validity once the vehicle is on UK soil.

The European leg of a personal import journey will not be covered by such insurance, and still cannot be covered by any UK insurer.  In effect, a Green Card is required for valid insurance cover outside the state in which a vehicle is insured.  Within the EC, by collective agreement, the insurance certificate - but note not a cover note - is deemed a Green Card.  For this reason, Green Cards, as such, are no longer issued on vehicles registered and insured within the EC, while making journeys wholly within the EC.  (If you stray outside the EC, however, you'll still need an actual Green Card.)

A temporary cover note, which is all that can be issued against a chassis number, does not have the status of a Green Card, and cannot cover journeys outside the state in which it is issued.  Thus, whatever people may be told by various insurance agents or their employees, a cover note issued by a UK insurer will only be valid once the vehicle is in the UK.  If you are assured to the contrary, and choose to proceed on that basis, it is imperative you get that assurance unequivocally confirmed, in writing, before you depart UK.  It will then fall to that broker's or agent's Professional Indemnity Insurer to pick up the pieces.  This is not a secure position in which to place one's self!

For the time being, therefore, the European leg of the journey must be insured separately, in the country in which the vehicle is purchased, and that insurance must be valid for all countries through which the vehicle will pass.  It is the duty of the vehicle owner to ensure this insurance is in place.  Having been told, or assured, to the contrary will not provide a legal defence against driving while uninsured in any state. 

Commonly, such insurances offer minimum third party cover only, which is to say they will only cover personal injury or accidental damage to third parties (i.e. not damage to the insured vehicle, or its driver, or occupant/s), and will not cover fire or theft.

The alternative, if such cover cannot be provided, will be to have the vehicle transported to the port of embarkation, where it should be unloaded within the port confines and may then be driven onto the ferry.  Once safely disembarked in UK, the vehicle will be fully covered, under its cover note, to the full extent of whatever insurance was bought.

Sorry for the above bits of megaphone communication: however the importance of these aspects was strongly emphasised to me during our conversation.

[Mel E]

Until the 5th Directive becomes UK Law, the position is as follows:

 

- EU insurers are permitted (under the 4th Directive) to provide 3rd Party cover for vehicles registered in another member state. The intention was to liberalise the motor insurance market. However, to do so, they must join the bonding scheme in each country that pays out claims against, inter alia, uninsured drivers. About 10% of our UK premiums go into that pot in the UK, run by the MIB (Motor Insurers Bureau)

 

- because of the costs and admin associated with bonding in each EU member state,no UK insurer has done it - not surprising, really!

 

- Hence UK insurers cannot write legal Third Party cover on foreign registered vehicles - you must get this from the state of temporary registration.

 

- The extra element that makes the policy 'COMPREHENSIVE' covers fire, theft and self-inflicted injuries to the driver and vehicle (and will usually cover you for Third Party injuries/damage if the latter cannot be found/ denies all knowledge., etc.). This is not included in Third Party insurance and is not covered by the Green Card which relates only to the mandatory Third Party cover.

 

- Hence, as I understand it, while UK insurers cannot provide Third Party cover for foreign registered vehicles, they can enter into a contract to provide fire, theft and vehicle and driver cover on foreign registered vehicles, none of which are covered by the various EU directives. That they choose not to do so is probably because of the additional complexity that writing a special policy would entail.

 

- Since the 5th Directive refers specifically to 'the insurance contract', I am assuming that this is the whole contract and not just the Third Party bit. I suspect that my assumption will not survive destructive testing, however.

 

Mel E

====

[PeterAndPatCue]

As Brian Kirby has inferred all the way through this thread, the only certainty with this issue is that there is uncertainty!

 

We at Comfort Insurance have been trying for months to get a clear answer to the sort of questions being raised here. Finally, today, we have managed to get some information from MIIC (Motor Insurance Information Centre), the organisation that runs the Motor Insurance Database (MID). Our concern has always been that any attempt to issue cover on a chassis number will fall foul of the MID requirement to submit details of any new policy/vehicle, complete with registration number, with 14 days of inception. A 30-day cover note showing a VIN only would prevent us from complying with this requirement, and if we fail to comply we face repercussions. You will not be surprised learn that we now find (from MIIC) that they consider this aspect of the 5th Directive unworkable and that they have sent the whole thing back to Brussels for reconsideration. In a nutshell, the 5th Directive makes the 4th Directive unworkable, and vice-versa. There is no known date for a resolution.

 

So far as Mel E’s point on UK insurers providing “balance of risk”, i.e. Fire Theft and Accidental Damage cover only, he is likely to be proved right that insurers will have little or no appetite for what is a very niche requirement.

 

[John Keats]

Which leads me to believe that many who object to the UK being fully part of Europe are traders and the like who gain financialy by keeping the UK seperated and at a distance.

 

We the general public would gain substantially by being fully integrated with the EU on many aspects.

 

When working I found I could buy identical overseas products 60% cheaper than internaly.

 

Its worked like the supermarkets and banks, be BRITISH BE LOYAL !

 

RUBBISH be mistrusting of traders who import.

[Derek Uzzell]

A startling leap of logic...

 

If we assume "traders" to refer to 'motorhome' traders (after all this is a motorhome forum, though, Heaven knows, I do wonder sometimes!) then obtaining insurance cover of the type being discussed in this thread is academic (at least for new motorhomes) as DVLA registration strictures pretty much compel professional importers to bring in the vehicles via transporters.

 

I believe that the cost of employing a transport company to deliver a motorhome from, say, Germany to a UK address is getting towards £1000. Obviously, if you are a 'private' motorhome importer prepared to drive the vehicle home yourself, you can flit over to Germany using a budget airline, get a cheap ferry crossing back and save a good chunk of that sum. However, doing it like that means you won't be able to insure your new motorhome 'comprehensively' until it reaches these shores and this (quite understandably) worries potential private importers.

 

As I understand it, it used to be possible (and legal) for UK private motorhome importers to obtain from UK insurers comprehensive cover from the point of sale abroad, but a revision to EU insurance regulations meant that, a few years back, UK insurers were (essentially) no longer in a position to provide 'total journey distance' comprehensive cover. It was hoped by UK insurers (who would dearly love to sell you a suitable policy if they legally could) and by potential private importers that another revision to the rules (the 5th Directive) would return matters to Square One but, from Peter Cue's helpful posting, it seems we are as deeply in the mire (perhaps even deeper!) now as before.

 

What I fail to comrehend is why any of this should have a bearing on the UK fully integrating into the EU (presumably this really means adopting the Euro as the UK currency) as the present insurance difficulty is, in fact, due to EU regulations to which the UK is already fully signed up to (Hmmm - a bit of odd English there, but you'll get the drift).

 

If we are going to bitch about motorhome price differences between the UK and Continental Europe, then what we need to do to equalise things is to switch the UK driving norm to the right-hand side of the road and fill in the English Channel. Then the European motorhome market would be on a level playing field and, if we disliked Auto-Sleepers' or Auto-Trail's high prices (for what would now be LHD vehicles of course) we could drive directly elsewhere in Europe for a cheap Adria or Hymer without being concerned about ferries or the Chunnel. Surely this makes much more sense and we wouldn't have to integrate any further into the EU to achieve it. In fact, filling in the Channel would be a very practical solution to our waste-disposal land-fill problems and, if it turned out there wasn't enough waste to do the job, we could tip in some of the bull**** that this forum regularly produces!

[Brian Kirby]

The directive was signed in May 2005, and published in June 2005, for implementation in June 2007.  Two years notice, yet the industry waits until the clock is striking midnight before raising its objections.  Not helpful!  Someone needs a good poke with a sharp stick, methinks.

It is strange that the person originating this post was given to understand temporary third party insurance could no longer be obtained, because this directive made it irrelevant.  Vehicles on temporary export registration plates now being insurable in their destination state until import formalities are completed. 

Seems other bits of Europe can make this work, while we cannot.  Despite this, our insurers now seem to think it is Europe's obligation to throw the lot away and start again.  Hmmmmmmmm.

I know what I'd be saying if I were a Eurocrat with responsibility for insurance.  I think it would go along the lines of "the consultation period has long since expired, the directive is now deemed part of your national legal framework, you're too late, so get on with it and fix your system so that it harmonises with the systems now in use elsewhere."   Dreams, dreams, dreams eh?