Motorhomes, DVLA and body types

We look at a problem panel van converters are having with the DVLA

Many of our readers are practical people, which often leads them into a DIY or professional conversion of a registered panel van to create a motorhome suiting their particular needs and budget. However, one task that is defeating more and more converters, including the professionals, is reregistering a panel van as a motor caravan with the

Driver and Vehicle Licensing Agency (DVLA), the government body responsible for registering vehicles.

REREGISTERING AS A MOTOR CARAVAN

What’s a bit of paperwork set against the practical problems of conversion? Not a lot unless you factor in the DVLA’s narrow and sometimes incomprehensible vision of what constitutes a motor caravan. The term ‘motor caravan’ is how the DVLA refers to a motorhome and this term is what should ideally be shown on the body type line of your V5C.

The DVLA confirmed to MMM early in 2020 that it had refused 9,488 applications to reregister a vehicle as a motor caravan during the first 11 months of 2019, yet for the whole of 2017 the number of rejections was just 622. It also stated it was unable to explain why there had been such a huge increase or what the main refusal issues had been. It did stress that vehicles that met all its criteria will be, and have been, reclassified as motor caravans. MMM also found many professional converters and private individuals contradicted this, saying their conversions meet all the criteria and have still been refused.

DVLA CRITERIA FOR MOTOR CARAVAN STATUS

The DVLA has strict criteria for what constitutes a motor caravan and only if it accepts a submission of evidence, including photographs, will it enter motor caravan onto a V5C. The best many converters can squeeze out of the DVLA is a reregistering of their vehicle body type as “van with side windows”. Details for the DVLA requirements are shown at gov.uk/ government/publications/convertinga-vehicle-into-a-motor-caravan

The DVLA’s stance is a motor caravan has not only to have the internal features of a motorhome, but have permanent external body features which in its words, “accurately reflect the vehicle’s appearance in traffic”. Internal attributes don’t appear to be an

obstacle to reregistration and most converters recognise the demands as reasonable.

Coachbuilts are by their nature clearly distinguishable from the base vehicle when built in the guise of a goods vehicle. But what is necessary to alter the appearance of a van in the case of a panel van conversion (PVC)? Another question could be why does a PVC need to stand out as a motor caravan in traffic?

One could argue that the DVLA’s requirement for an awning rail is hardly noticeable in traffic hence is of little consequence. Even where converters fit a roll-out awning (which usually include an awning rail in the cassette face), this is disregarded by the DVLA. And the norm is for an application to be turned down without a stated reason.

A READER’S EXPERIENCE

One of the great assets of a specialist magazine like MMM is its readers who send in their motorhoming experiences, which can challenge and motivate us.

Reader, John Chaffe, is typical. He’s been corresponding with the DVLA to get his professionally converted Ford Transit van registered as a motor caravan. After reading my reader response in September’s MMM about the likelihood of being fined if exceeding speed limits set for goods vehicles unless your V5C body type is shown as motor caravan, he wrote in about his exasperating experience with the DVLA.

He submitted all the details the DVLA requested, including photographs as shown in this article, but only received a change of body type to van with side windows. As far as John was concerned (and I agree), all the DVLA’s requirements had been met. There isn’t a discernible awning rail but there is a cassette awning fitted, something far more obvious in traffic. There’s no process for appeal and no detailed reason why the reregistration to motor caravan was unsuccessful. The DVLA was satisfied by the internal changes but said, “externally the vehicle does not have the permanent external features to be described as a motor caravan”.

The DVLA went on to say, “With regards to the speed limits applicable to motor caravans... speed limits for different categories of road vehicle depend on how the vehicle is configured for use on the road. If you, as the registered keeper, are satisfied that the vehicle meets the definition of a motor caravan … then you can operate it as such regardless of what it is classified as in the body field.”

This seems a little vague and John is justifiably worried that if picked up as travelling at 70mph on a dual carriageway, who are the police going to believe, his claim the vehicle is defined as a motor caravan or what they can see on the V5C.

The DVLA’s website also states, “The body type does not affect the insurance category of the vehicle, or have any effect on speed limits or other legislative requirements. It is only used for establishing vehicle appearance and identification.”

THE DEPARTMENT FOR TRANSPORT’S VIEW

To check the DVLA’s approach, I contacted the Department for Transport (DfT), which deals with speed limit legislation and it confirmed the speed limit for a vehicle is not connected to the body type on the V5C registration form.

The national speed limits for different categories of road vehicle depend on how the vehicle is configured for use on the road. The legislation applicable is the Road Traffic Regulation Act 1984, Schedule 6, which lists vehicle types that are restricted to speeds below the national speed limits.

If a van meets the definition of a motor caravan in accordance with the link below then it needs to comply

with the speed limit for the type of vehicle (ie motor caravan) dependent on its weight gov.uk/government/ publications/registering-a-diycaravan/converting-a-vehicle-into-amotorhome

The Road Traffic Act 1984, schedule 6 refers to Regulation 2(1) of the Motor Vehicles (Type Approval)(Great Britain) Regulations 1979 which defines a motor caravan as “a motor vehicle which is constructed or adapted for the carriage of passengers and their effects and which contains, as permanently installed equipment, the facilities which are reasonably necessary for enabling the vehicle to provide mobile living accommodation for its users.”

So, both the 1979 regulation and the DfT provide the legislative outline for the definition of a motor caravan for purposes of speed limits and both definitions refer only to internal fittings not external appearance.

I also asked the DfT if it could offer any reassurance that the police were aware of these requirements. Its response was, “This is a matter for the police to respond to.”

THE POLICE RESPONSE

I put the question of speed limits and panel van conversions into the help box of askthe.police.uk an official police website for England and Wales. And the forthcoming answer was:

“Check that the V5C registration document has been changed to ‘motor caravan’, otherwise you’ll be subject to the same speed restrictions as the van it’s based on. However, even if it states motor caravan on the V5, if you drive such vehicles at the same speed limits as a car, some police forces may take action against you for speeding. You will then have to prove to them and ultimately a court that the vehicle is a campervan – this may not be an easy thing to do. For this reason, if you have a campervan that is converted from a panel van, to avoid any difficulties, many organisations will suggest that you stick to the same speed limits that apply to a van.”

AN EXPERT VIEW

As the above shows there are mixed messages. To try to gain further clarity I spoke to industry expert, Tim Booth. Tim has 30 years of experience as a police officer dealing largely with caravan and motorhome thefts, with much time having been spent educating police officers throughout the country about leisure vehicles. He now runs his own consultancy firm providing his expertise to the National Caravan Council (NCC) and the National Vehicle Crime Intelligence

Service (NaVCIS) and he can often be seen at shows offering advice.

Tim agrees that most speeding offences are now flagged up by cameras and, as such, images are taken of front or rear views and to expect a police officer to note a van has been fitted with an awning rail is impossible or impractical. Representations have been made to the DVLA about this issue with suggestions that roof lights or pop-up features would be more discernible when reviewing camera images, but the DVLA declined to respond. He also believes side graphics are misleading as they are too easily removed or replaced as a cost-effective way of disguising a stolen motorhome.

Tim believes better information on the V5C could be useful with the work of tracing stolen vehicles, but the DVLA’s standard response is “impossible”. His suggestion to resolve this is a body type for a PVC motorhome as Window Van (Motor Caravan) but this would require additional fields of input and it is believed DVLA’s IT platform is not able to deal with additional information. Whilst this IT capacity problem remains, any change is unlikely any time soon.

Tim thinks it’s likely, when images captured on a camera are reviewed, that a motorhome with a V5C body

type shown as van with side windows will be viewed as a non-commercial van. If this is not picked up then Tim says the owner can present relevant photographic evidence as part of their defence, which will be admissible.

THE NCC VIEW

The NCC represents mainstream motorhome builders, which largely convert new vehicles working through the Type Approval system and subsequently undertake first-time registrations with the DVLA. So far, where manufacturers have gained European Whole Vehicle Type Approval (EWVTA) and use the DVLA’s automated RaV (register a vehicle) system, there’s not been an issue.

The NCC is concerned the DVLA’s definition of a motor caravan is not in line with definitions within the directives for EWVTA. There is also another issue for the NCC regarding the quality of conversions on preregistered vans, which do not require any approval. Thus, if the DVLA does change the status of a conversion to that of motor caravan, the NCC considers it may be seen as condoning unsafe conversions and possibly dangerous vehicles.

The NCC is taking up these issues with the DfT and the DVLA to try to achieve a better registration process and hopefully more checks to ensure non-type approved conversions are safe.

DVLA COMMENT

When contacted, the DVLA repeated information on its website, “The body type information held on the vehicle record must describe what a vehicle actually looks like in traffic. Therefore, the body type will not be changed unless the exterior of the vehicle actually appears to be a motorhome.”

When asked whether the DVLA is discriminating against smaller panel van converters while larger manufacturers with type-approved motorhomes appear to automatically receive motor caravan status, despite the outward appearances being similar, a spokesperson said, “I can confirm that each decision is based on the information and evidence provided and not on who is submitting the application.”

SUMMARY

It’s clear from statements issued by the DVLA and DfT that the V5C body type of van with side windows does not preclude the acceptance of your motorhome as a motorhome for speed limit and other purposes. However, as a standard and legally required document, the V5C offers an ideal opportunity to avoid any problems with the police. It’s a document where photographic evidence needs to be submitted, it’s easily accessible by the police and provides reassurance to motorhome owners of the status of their vehicle. The opportunity to make life easier for everyone is being missed. Hopefully, the NCC will be successful in its attempts to produce a better registration system, which could potentially also regulate small converters in a way to benefit consumers and lessen the possibility of unsafe conversions being sold.

In the meantime, if you have received a “van with side windows” registration then retain a copy of your submission to the DVLA with photos ready to submit in the case of a speed limit notice with reference to the relevant legal definition of a motor caravan for speed limit purposes.