GB Type Approval: A Post-Brexit Era for the UK Automotive Industry

Notice to readers: this document was produced by artificial intelligence and does not constitute legal or regulatory advice.

The introduction of GB Type Approval heralds a new chapter for British automakers, reshaping the legislative landscape in a post-Brexit Britain. This reform promises to redefine regulatory standards and has significant implications for the UK automotive manufacturing sector. It provides a platform for greater innovation and international competitiveness, but also presents challenges, particularly with the rising uptake of electric vehicles and the impending implementation of Euro 7 standards. Policymakers need to be aware of these implications to make informed decisions that will shape the future of the industry.

What is GB Type Approval?

GB Type Approval is a regulatory framework designed for manufacturers planning to market vehicles and their components within Great Britain. This scheme is pivotal as it mandates adherence to specific safety, environmental, and performance standards before vehicles can be sold in Great Britain. For regulatory compliance officers, comprehending and executing GB Type Approval is a crucial aspect of their role, underscoring their significance in ensuring the industry operates within the mandated standards.

Key Aspects of GB Type Approval:
  1. Legislative Basis: The scheme is grounded in EU legislation as retained in UK law post-Brexit on December 31, 2020. It also incorporates any subsequent UK legislation that amends or supplements the retained EU laws.
  2. Scope and Application: GB Type Approval currently applies under the 2018/858 framework regulation, which includes motor vehicles and trailers in the M, N, and O categories, along with their systems and components.
  3. Approval Routes: There are two simplified approval routes for limited production volumes:
    • GB Medium Series Approval: For M1 or N1 vehicles with production under 1500 units annually.
    • GB Small Series Approval: Available for all vehicle categories, with production caps at 250 or 500 units depending on the category.

 

Implementation and Compliance:
  • Phased Introduction: The introduction of the GB Type Approval is being phased. A full application is required for new vehicle types starting February 1, 2024.
  • Approval Holder Requirements: To hold a GB Type Approval, the approval holder must be based in Great Britain or appoint a representative who is.
  • Provisional Approvals: Manufacturers using provisional GB type approval, which recognises vehicles approved to EU standards, must transition to full GB Type Approval by specific deadlines. For motor vehicles, this transition must occur for new models by February 1, 2024, and for all models by February 1, 2026.

 

This framework ensures that all vehicles sold in Great Britain meet rigorous standards, promoting safety and environmental sustainability in the automotive industry.

The Evolution of GB Type Approval Post-Brexit

The departure of the UK from the European Union has necessitated significant adjustments in the regulatory framework for vehicle type approvals, fundamentally altering the landscape for British automotive manufacturers. Post-Brexit, the UK is no longer recognised as an EU approval authority, which has profound implications for how vehicles are certified and sold within and outside the UK.

Key Changes in GB Type Approval Post-Brexit
  1. Economic Operator Identification: Since the UK’s exit from the EU in March 2019, UK-based vehicle manufacturers are required to appoint a representative within the EU to interact with Member State type-approval authorities. This change mandates a new layer of representation for UK manufacturers to ensure their vehicles can be marketed within the EU.
  2. Competence of UK Authorities: With the UK’s departure from the EU, it ceased to be recognized as an EU approval authority. This shift in status means that the Vehicle Certification Agency (VCA), the UK’s type approval body, is no longer authorized to issue EU type-approvals. British manufacturers are now required to seek type-approval from EU member states to market their vehicles in the EU, a significant change in the regulatory landscape.
  3. Impact on Manufacturers: The need for separate type approvals from EU authorities imposes additional burdens on UK manufacturers, including increased costs and extended timelines. The average cost for approval of a standard car ranges between £350,000 and £500,000, and the process can take from 6 to 18 months. This requirement not only adds financial strain but also operational delays.

 

Strategic Adjustments and Future Directions

The UK now has the opportunity to tailor its vehicle regulation system to better meet the specific needs of its market while adhering to international safety and environmental standards. The future strategy includes:

  • Adapting to International Standards: Leveraging the flexibility to standardise vehicle standards at the international level through the UNECE, while also recognising standards and tests from other global entities.
  • Encouraging Innovation: The GB Type Approval aims to support innovation and the development of SMEs by simplifying the approval process and reducing the regulatory burden.
  • Environmental and Safety Enhancements: Continued emphasis on enhancing vehicle safety, security, and environmental performance aligns with the government’s broader transport and environmental policies.

 

These strategic shifts underline the UK’s commitment to maintaining robust vehicle standards post-Brexit, ensuring that the vehicles meet domestic needs and compete effectively in international markets.

Key Principles and Objectives of GB Type Approval

Standardisation through UNECE

The GB Type Approval primarily aligns with the United Nations Economic Commission for Europe (UNECE) regulations, which encompass approximately 75% to 80% of the subject areas for passenger vehicles. The intention is to fully apply all relevant UNECE regulations, significantly reducing the resources and costs associated with negotiating new regulations into law. This strategic alignment facilitates a more streamlined approach to vehicle standardisation, ensuring that vehicles meet rigorous international safety and environmental standards while simplifying the approval process for manufacturers.

Flexible Approach to Recognising Global Standards

In scenarios where UNECE standards do not prevail, the GB Type Approval scheme adopts a flexible approach, allowing for the deregulation of low-risk areas and the acceptance of alternative national standards. This includes standards from the EU and other jurisdictions, with an ongoing analysis to identify and adopt standards from different countries. This approach enables manufacturers to seek approval in multiple markets using a single test report, thereby avoiding the need to repeat testing and reducing overall compliance costs.

Bespoke Domestic Requirements for Local Benefit

Domestic legislation plays a crucial role in addressing specific concerns that are most pertinent to GB manufacturers and consumers. This bespoke approach allows for the rapid introduction of new technologies and the implementation of robust safety and environmental standards at a pace that exceeds international efforts. By focusing on local benefits, the GB Type Approval scheme ensures that it not only meets international compliance but also supports UK businesses and consumers by fostering innovation and ensuring market readiness for new automotive technologies.

Future Outlook and Impact on the Automotive Industry

The GB Type Approval system is not just a regulatory change but a potential catalyst for economic growth, job creation, and technological innovation in the UK automotive industry. This impact is anticipated to be particularly profound, offering a promising future for the industry and its stakeholders.

Economic Growth and Job Creation

According to the government, implementing effective vehicle regulations under the GB Type Approval is expected to stimulate economic growth and create substantial employment opportunities across Great Britain. The development and integration of self-driving vehicles are projected to be a significant contributor to this growth. By 2035, the autonomous vehicle sector alone could add approximately £40 billion to the economy and generate around 38,000 skilled jobs across various regions. This expansion hinges on a regulatory environment that is both clear and predictable, enabling businesses to innovate confidently and invest in new technologies.

Supporting SMEs and Compliance

The Department for Transport’s ambition to foster the future of transport is closely aligned with the objectives of the GB Type Approval. The framework supports broader economic objectives by facilitating innovation and aiding the development of small to medium-sized enterprises (SMEs). Additionally, it focuses on improving enforcement measures to ensure compliance, thereby maintaining high standards of safety and environmental responsibility within the industry.

Technological Innovation and Legislative Compatibility

As technology and software become increasingly central to automotive development, particularly with the shift towards automated vehicles, the need for a supportive legislative framework becomes critical. The GB Type Approval aims to provide this by enabling the safe introduction of new vehicle designs and technologies. However, there is a risk that innovation and associated investment could be hindered if the legislative framework fails to keep pace with technological advancements. Ensuring compatibility between new vehicle designs and existing legislation is essential to avoid delays and maintain the UK’s competitive edge in automotive manufacturing.

Next steps

The UK Department for Transport will run a stakeholder engagement process over the coming months. This will be done in three phases.

The initial stage entails a focused solicitation of evidence to procure feedback on the suggested reforms, aiming to ascertain methods for achieving the vision with minimal burden and facilitating growth. This will involve engagement with stakeholders from the industry, academia, and safety and environmental organisations.

Subsequently, the second stage will see the execution of specialised workshops with each group of stakeholders to refine insights and incorporate additional technical specifics. These sessions will concentrate on particular topics, including the impact on the industry, safety and environmental issues, technological innovation, and administrative load.

The evaluation stage will guarantee a thorough and empirically based examination of the reform’s implications.

Conclusion

The introduction of GB Type Approval represents a pivotal movement towards reshaping the UK’s automotive landscape in the post-Brexit era, tailoring the regulatory framework to foster innovation, environmental sustainability, and international competitiveness.

Yet, as with many post-Brexit reforms, businesses may find that the new GB Type Approval adds to their regulatory burden when doing business in Great Britain and when exporting products from GB to the European Union and other key markets.

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