FTA Briefing Note

Changes to roadworthiness tests from 2012

On 5 July 2010, the European Commission adopted a directive aimed at adapting the standards and methods applicable to roadworthiness tests for motor vehicles and trailers. This directive amends Annex II of Directive 2009/40/EC which is intended to harmonise vehicle and trailer roadworthiness tests across member states, laying down compulsory test items to be included which they must implement by 31 December 2011. The directive also lays down mandatory information which is required to be included on roadworthiness test certificates. This briefing note is aimed at providing members with a summary of the changes which will affect the roadworthiness testing of vehicles and trailers ahead of the legislation being implemented.

BackgroundThe in-service roadworthiness (annual) •inspection carried out by the Vehicle and Operator Services Agency (VOSA) is cur-rently legislated through Directive 96/96/EC. This establishes the testing require-ments for member states including the timescale for testing and what aspects of a vehicle are to be tested

Directive 96/96/EC has been substan-•tially amended several times, and since the Commission proposed further amendments, the decision was made to recast the direc-tive in the form of 2009/40/EC for clarity

Since its entry into force, the Commission •has reviewed Directive 2009/40/EC and decided that it should be further defined and adapted to reflect technical progress, in order to improve motor vehicle road-worthiness testing across member states. This has resulted in the adoption of Directive 2010/48/EU which amends Annex II of Directive 2009/40/EC

What will be the impact on annual testing?The directive presents new challenges which will impact upon VOSA’s testing and enforce-ment strategies and will introduce new items into the statutory vehicle test. The statutory test currently covers items relevant to the design, construction and equipment of the tested vehicle. The new directive will mean a review of the additional safety, security and environmental factors, introducing new test items and new reasons for failure of the annual test. In order to maintain a satisfac-tory level of road safety in Great Britain, the Department for Transport (DfT) and VOSA are reviewing the annual test to find the best ways of meeting the directive’s requirements whilst minimising the impact on the annual test.

Content of Directive 2009/40/EC as amended by Directive 2010/48/EUThe new directive identifies the vehicle sys-tems and components to be tested. It details the method of testing them and the criteria to be used when determining whether the condition of the vehicle is acceptable.

The directive mandates that the roadworthi-ness test must cover at least the following items.

0 Identification of the vehicle

1 Braking equipment

2 Steering

3 Visibility

4 Lighting equipment and parts of electric system

5 Axles, wheels, tyres, suspension

6 Chassis and chassis attachments

7 Other equipment

8 Nuisance (eg noise and exhaust emissions)

9 Supplementary tests for passenger carry-ing vehicles M2 and M3

For all test items, the directive includes a non-exhaustive list of the main reasons for failure and requires the vehicle operator or driver to be notified in writing of the defects; the result of the test will be included into the roadworthi-ness certificate.

ScopeThis directive concerns roadworthiness tests for the vehicle and trailer types specified in table 1 overleaf.

Notwithstanding the mandatory require-ments of the directive, member states are permitted to:

bring forward the date for the first com-•pulsory roadworthiness test and, where appropriate, require the vehicle to be sub-mitted for testing prior to registration

shorten the interval between two succes-•sive compulsory tests

make the testing of optional equipment •compulsory

increase the number of items to be tested•

extend the periodic test requirement to •other categories of vehicles

prescribe special additional tests•

set higher minimum standards for braking •efficiency than those specified in Annex II of the directive for vehicles registered on their own territory

ExemptionsExemptions exist which allow member states to exclude from the scope of the direc-tive vehicles belonging to the armed forces, forces of law and order and the fire service. Member states may also, after consulting with the Commission, exclude from the scope of the directive certain vehicles operated or used in exceptional conditions and vehicles which are never, or hardly ever, used on public highways, including vehicles of historic interest which were manufactured before 1 January 1960 or which are temporarily withdrawn from circulation.

To ensure that the various categories of exemption in GB law are compatible with this directive, in December 2009 the Department for Transport consulted on the proposed removal of exemptions from GB annual test-ing for certain vehicle types. Details of this consultation can be found at www.dft.gov.uk/consultations/closed/mottestingexemptions

Changes to roadworthiness tests from 2012

2 An FTA Briefing Note

Date of entry into forceThe changes and requirements of the directive (with the exception of changes to the road-worthiness certificate) will come into force on

31 December 2011. The changes to harmonise the roadworthiness certificate will apply from 31 December 2013.

Compulsory items to be tested Annex II of the directive identifies the vehicle sys-tems and components to be tested, the method of testing them and the criteria to be used when determining whether the condition of the vehi-cle is acceptable. The inspection is required to cover at least the items listed in Annex II pro-vided they are related to the installed equip-ment of the vehicle being tested. ‘Reasons for failure’ do not apply in cases where they refer to requirements which were not prescribed in the relevant vehicle approval legislation at the time of first registration, first entry into service or retrofitting requirements.

The table below lists the changes and addi-tional test items2 detailed in Annex II of the directive that do not currently feature in GB roadworthiness testing of hgvs and psvs. which will be included in roadworthiness tests from 1 January 2012.

Item (Item number specified in directive)

Method of inspection Additional reason for failure

0 Identification of the vehicle

0.1 Registration numberplates (if needed by requirements)

Visual inspection Numberplate(s) missing or so insecure/fixed that it is (they •are) likely to fall off Inscription missing or illegible•Not in accordance with vehicle documents or records•

1 Brakes

1.1.1 Service brake pedal/hand lever pivot Visual inspection of the components while the braking system is operated

Service brake pedal/hand lever pivot too tight•

1.1.2 Pedal/hand lever condition and travel of the brake operating device

Visual inspection of the components while the braking system is operated

Brake control not releasing correctly•

1.1.10 Brake servo units, master cylinder (hydraulic systems)

Visual inspection of the components Brake fluid warning light illuminated or defective •Insufficient brake fluid •

1.1.15 Brake cables, rods, levers, linkages Visual inspection of the component Cable guide defective•

1.1.16 Brake actuators (including spring brakes or hydraulic cylinders)

Visual inspection of the component Dust cover missing or excessively damaged to the extent that •leakage is likely

1.1.19 Endurance braking system (where fitted or required)

Visual inspection of the device, its contacts and components for security, clearance, signs of over-heating, condition of wiring and any material leaks

Missing when known to be mandatory •Inoperative, damaged, component missing or insecure•Wiring insecure, or damaged•

1.7 Electronic braking system (EBS) Visual inspection of the component Warning device illuminated indicating a malfunction •EBS lead missing where required•

2 Steering

2.1.3 Steering linkage condition With the vehicle over a pit or on a hoist and with the road wheel on ground, rock steering wheel clockwise and anti-clockwise or using a specially adapted wheel play detector. Visual inspection of steering components for wear, fractures and security

Dust cover missing or excessively damaged to the extent that •lubricant leakage is likely

Categories of vehicleMinimum frequency

of tests1

Motor vehicles used for the carriage of passengers and with more than eight seats, excluding the driver’s seat

One year after the date on which the vehicle was first used and thereafter annuallyMotor vehicles used for the carriage of goods and having a maximum permis-

sible mass exceeding 3,500kg

Trailers and semi-trailers with a maximum permissible mass exceeding 3,500kg

Taxis, ambulances

Motor vehicles having at least four wheels, normally used for the road car-riage of goods and with a maximum permissible mass not exceeding 3,500kg, excluding agricultural tractors and machinery

Four years after the date on which the vehicle was first used and thereafter every two yearsMotor vehicles having at least four wheels, used for the carriage of passengers

and with not more than eight seats excluding the driver’s seat

Table 2: Test items/reasons for failure/changes not subject to current GB roadworthiness tests applicable from 1 January 2012

Note: items listed in the table are applicable to the heavy goods vehicle/passenger carrying vehicle test.

1 Minimum frequency of tests as stated in the directive. At the time of writing FTA understands that DfT has no intention of changing current testing frequencies, which for some vehicle categories are more frequent than the minimum requirement stated in the directive.

2 The full list of compulsory test items (which includes items which are already inspected in GB roadworthiness testing) is contained within Annex II of Directive 2009/40/EC as amended by 2010/48/EU.

Table 1: Categories of vehicles and frequency of tests

Changes to roadworthiness tests from 2012

An FTA Briefing Note 3

Item (Item number specified in directive)

Method of inspection Additional reason for failure

2.1.5 Power steering Check steering system for leaks and hydraulic fluid reservoir level (if visible). With the road wheels on ground and with the engine run-ning, check that the power steering system is operating

Absence or hydraulic fluid level below minimum•

2.6 Electronic Power Steering (EPS) Visual inspection and consistency check between the angle of the steering wheel and the angle of the wheels when switching on/off the engine

EPS malfunction indicator lamp (MIL) indicates any failure in •the system

4 Lighting

4.7.1 Rear registration plate lamp – condition and operation

Visual inspection and by operation Lamp showing a white light to the rear•

4.8.1 Conspicuity (retro reflecting) markings – condition and compliance

Visual inspection Not fitted where required •Reflecting equipment defective or damaged •Reflective equipment insecure •

4.9.1 Main beam tell-tale – condition and operation

Visual inspection Tell-tale inoperative•

5 Suspension

5.3.4 Suspension joints Visual inspection Dust cover missing or excessively damaged to the extent that •lubricant leakage is likely

6 Chassis and chassis attachments

6.1.3 Fuel tank and pipes (including heating fuel tank and pipes)

Visual inspection with vehicle over a pit or on a hoist, use of leak detecting devices in case of LPG/CNG systems (use of leak detection device in cases to support failure of LNG)

Major leak of CNG/LPG/LNG•

6.1.7 Transmission Visual inspection Dust cover missing or excessively damaged to the extent that •lubricant leakage is likely

6.2.5 Driver’s seat Visual inspection and by operation Driver's seat unable to be adjusted in the for or aft direction•

7 Other equipment

7.1.3 Safety belt load limiter Visual inspection Load limiter obviously missing•

7.1.4 Safety belt pretensioner device Visual inspection Pre-tensioner obviously missing or not suitable with the •vehicle

7.1.5 Airbag Visual inspection Airbag(s) obviously missing•

7.1.6 SRS systems Visual inspection SRS MIL indicates any kind of failure of the system•

7.9 Tachograph (if fitted/required) Visual inspection and comparison with tacho seal Size of tyres not compatible with calibration parameters•

7.12 Electronic Stability Control (ESC) if fitted/required

Visual inspection Components missing or damaged •Switch or wiring damaged or malfunctioning •ESC MIL indicates any kind of failure in the system•

8 Nuisance

8.2.2.1 Exhaust emission control equipment Visual inspection Emission control equipment fitted by the manufacturer absent •or obviously defective

9 Other

Brake testing to maximum authorised mass

Changes to roadworthiness tests from 2012

Passenger carrying vehiclesAnnex II of the directive also specifies supple-mentary tests for passenger carrying vehicles of categories M2 and M3. In the main these include recommended items which are related to the condition of the vehicle and its suitability for use on the road but which are not considered essential in a periodic test. Full details of these items are listed in Annex II of the directive.

Roadworthiness certificatesRoadworthiness certificates issued in case of mandatory periodic vehicle tests are required to cover at least the following elements.

Vehicle Identification Number (VIN) •

Registration plate number and country sym-•bol of state of registration

Place and date of the test •

Odometer reading at time of the test if •available

Vehicle class if available •

Identified defects (it is recommended to fol-•low the numerical order of paragraph 5 of the Annex) and its category

Overall assessment of the vehicle •

Date of next periodical test (if this informa-•tion is not provided by other means)

Name of inspection organisation and signa-•ture or identification of the inspector respon-sible for the test

The directive requirements regarding harmo-nised roadworthiness certificates will apply from 31 December 2013.

Commission recommendation on the assessment of defects during roadworthiness testingThe Commission has also published a recom-mendation paper stating that member states

should assess deficiencies and failures detected during a roadworthiness test of motor vehicles and trailers.

The recommendation states that inspectors conducting vehicle testing should be provided with guidelines in order to ensure a harmonised assessment of the failures listed in Annex II of the directive. To reflect the seriousness of fail-ures, it recommends that three categories of fail-ures should be introduced, with each category of failure containing the conditions for the fur-ther use of the vehicle.

Guidelines for the assessment of defects and definitionsThe guidelines for assessing failures, including technical defects and other non-compliances, that are found during periodic testing of vehicles are categorised in three groups.

Minor defectsTechnical defects that have no significant effect on the safety of the vehicle and other minor non-compliances. The vehicle does not neces-sarily have to be re-examined as it can reason-ably be expected that the detected defects will be rectified without delay.

Major defectsDefects that may prejudice the safety of the vehicle or put other road users at risk and other more significant non-compliances. Further use of the vehicle on the road without repair of the detected defects is subject to conditions. The competent authorities in the member states must adopt a procedure for setting the con-ditions under which the vehicle may be used before passing another roadworthiness test.

Dangerous defectsDefects that constitute a direct and immedi-ate risk to road safety such that the vehicle

should not be used on the road under any circumstances.

Roadside inspectionsTo coincide with the adoption of the roadworthiness testing directive, the Commission have also adopted Directive 2010/47/EU which amends Directive 2000/30/EC on the roadside roadworthiness inspection of commercial vehi-cles. This amendment further defines improve-ments to roadside inspections in the European Union, and in particular lays down the rules for checking braking systems and exhaust emis-sions during roadside inspections. There are also requirements on the information contained on inspection reports. The Commission has also published a recommendation paper (similar to that detailed above for roadworthiness tests) including a list of guidelines for assessing defects that are found during roadside inspections of commercial vehicles. The changes will apply from 1 January 2012.

Next stepsDfT and VOSA are now looking at the annual test to find the best ways of meeting the requirements of the directive, whilst minimis-ing the impact on the annual test. FTA will be engaging with DfT and VOSA and will inform members of any developments and details of how the requirements of the directive will be transposed into GB legislation.

Further informationFull details of the relevant legislation and rec-ommendations can be accessed at the following web page of the Official Journal of the European Union:

http://eur-lex.europa.eu/JOHtml.do?uri=OJ:L:2010:173:SOM:EN:HTML

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