# UK re-classification to EV with DVLA



## Immo1282 (Jul 12, 2019)

I don't have a definitive answer - apart from being in exactly the same position and being fed similar (and often conflicting) information.

Here's the transcript I had with the DVLA after a conversation earlier in the year.

It seems that post 2002 conversions as you mentioned are kind of screwed here. The law needs an overhaul as it's clearly written to target the kind of modifications that increase emissions - not completely eliminate them.


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## john61ct (Feb 25, 2017)

Be grateful DIY conversions are even allowed at all


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## Eddie49 (Dec 6, 2018)

Also not definitive, but some more info here:
https://www.speakev.com/threads/uk-diy-ev-conversions-why-so-few-testing-requirements.140308/


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## eUKenGB (Feb 21, 2019)

Immo1282 said:


> I don't have a definitive answer - apart from being in exactly the same position and being fed similar (and often conflicting) information.
> 
> Here's the transcript I had with the DVLA after a conversation earlier in the year.
> 
> It seems that post 2002 conversions as you mentioned are kind of screwed here. The law needs an overhaul as it's clearly written to target the kind of modifications that increase emissions - not completely eliminate them.


But in your case, a 2003 vehicle is (in the end) accepted for electric VED (i.e. £0). Where's the post 2002 problem?

I have read gov/DVLA info stating post 1 Mar 2001 (which I think is the actual watershed in question) vehicles need to provide evidence of the conversion which makes sense as after that date, VED is all emissions based. But it doesn't specifically mentioned earlier vehicles, registered prior to that date and whose VED is based on engine size. So how's that going to work. In any case, I cannot find anything that specifies later vehicles cannot have their VED changed.

It's an unbelievable mess and since this is fundamentally actual British law, there needs to be a definitive ruling on the matter. Apart from repeatedly asking DVLA for clarification and getting different answers each time, I'm not sure how to achieve this.

Their suggestion? Write to them in the post. I despair.


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## eUKenGB (Feb 21, 2019)

john61ct said:


> Be grateful DIY conversions are even allowed at all


Well maybe, but what's the point if you still pay the same VED, while small ICE powered cars which do continue to pollute are getting it for nothing.

Utter shambles.


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## eUKenGB (Feb 21, 2019)

Eddie49 said:


> Also not definitive, but some more info here:
> https://www.speakev.com/threads/uk-diy-ev-conversions-why-so-few-testing-requirements.140308/


Yes I had read that, but no actual information about the problem, except a comment that there's a new department been set up at the DVLA to deal with conversions. A fact which was denied by the DVLA support person I spoke to yesterday and who told me their Policy Department had no policy on the matter. Brilliant.

I've asked the poster of that comment to help with info about how to contact this new department.


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## favguy (May 2, 2008)

I'd drop skooler (Mike) on here a PM and ask about this, he got up to speed with EV's on here  and now heads up indra.co.uk and should be up to date regarding the current situation regarding this. 

With all the fabulous later model sports cars that would make great EV's today, there must be a reason why commercial converters are only using much older classic cars... I suspect the Bureaucracy wall for the later cars might be insurmountable!

Sorry I can't help much, my conversion was a 1994 car, done a few years ago now and the only requirement at the time was proof the car was indeed now an EV running on battery power alone. This easily proved by a letter from a VAT registered garage confirming they'd inspected the car and this was indeed the case along with a few pictures.


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## brian_ (Feb 7, 2017)

favguy said:


> With all the fabulous later model sports cars that would make great EV's today, there must be a reason why commercial converters are only using much older classic cars... I suspect the Bureaucracy wall for the later cars might be insurmountable!


The other factor might be the difficulty of making a modern car, which is a rolling computer network, work properly without an operating engine and its controls.


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## favguy (May 2, 2008)

brian_ said:


> The other factor might be the difficulty of making a modern car, which is a rolling computer network, work properly without an operating engine and its controls.


Yes, much more involved than an older car for sure. My own preference to get around this would be to strip out all the donors control systems leaving basically the shell and then to build in all the systems in full from a suitable salvage EV that I'd be using as the "kit".

I've just done a little digging on the topic at hand and it seems the issue is with any car that has a specific emission figure on the registration document, rather than the older system of grouping based on emission bands, so anything after about 2000. If in doubt check the registration document of the donor, if it has an actual figure present, you can't presently change the taxation class at all due to some bureaucratic nonsense without putting the car through an individual type approval, which will be both hideous (as my understanding is you will then have to prove compliance with current electromagnetic interference rules in force for current production EV's), and hideously expensive!

Cars on the older pre 2001 system currently still only require proof of the change to EV and that it has been done in a safe and professional manner. Passing an MOT test and a letter from a garage along with photo's should still do it.


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## eUKenGB (Feb 21, 2019)

I have been having something of a ding-dong argument with DVLA over the last few months (everything's slow due to COVID) regarding the conversion of ICE vehicles to electric. First of all, motorcycles are different and it would appear to be no bother getting any bike re-classified as electric. Cars however…

Essentially there are different 'rules' for cars first registered within 3 different date ranges, all specified in the 'Vehicle Excise and Registration Act 1994'. An important point, clearly stated in VERA being that "electrically propelled vehicles are exempt from paying Vehicle Excise Duty". So the issue is whether any such conversion will be re-classifed as 'Electric' :-

Pre 1 Mar 2001
Rates are based on engine capacity but once a car is converted to all electric and DVLA are satisfied this has been done (receipts etc from work done and/or other verification from whoever did the conversion may be required) the car can be re-classifed as 'Electric' and pay no more VED.

Post 31 Mar 2017
Have not looked into this deeply as it is an unlikely scenario (cars too new to be worth converting), but there are specific provisions for electric cars. However I have not asked for clarification on conversions from ICE, for the aforementioned reason. I doubt this era is of concern to us, but the implication is that a converted vehicle could be re-classified as 'Electric'.

1 Mar 2001 - 1 Apr 2017
This is the tricky period as I think it encompasses a lot of cars that would be highly suitable for conversion. The problem is that cars first registered within the above dates are taxed according to CO2 emissions and for this class of vehicle this figure CANNOT be altered on the registration docs for the life of the car. Hence DVLA say even if a car is converted, they will not change the Taxation Class to electric and will continue to demand VED at the current rate for that emissions class - even though it now produces 0% CO2. This is stupid.

Not only only that, but it is my contention that they are interpreting the regulations incorrectly. The way it is actually worded states that an electric vehicle is exempt and there are NO exceptions to this. It does NOT state that it is inapplicable to cars first registered within the above date range. So being electric means exempt and hence there is no need to then even consider the schedule that governs VED for various emissions classes and other areas that state the emissions figure cannot be changed. I have taken legal advice on this and the opinion is that being electric is an overriding condition and therefore any converted vehicle should be exempt. So I am not alone in interpreting the regs this way.

Unfortunately, DVLA does not agree and continues to interpret VERA how they always have and will not shift their opinion, convinced they are in the right. Not only that, but in the course of our discussion, I found they were supporting their view by incorporating additional restrictions that simply do not exist within the regs. Like claiming the Taxation Class cannot be changed, although VERA states no such thing. The CO2 emissions figure cannot be changed, but there is nothing preventing them from simply altering the TC to 'Electric' which would then mean the emissions figure is simply irrelevant. I cannot see any stated reason that this age of car should be treated differently from the earlier cars, also for which there is no specific provision for electrically propelled vehicles. They obviously have no 'capacity' so that simply becomes irrelevant once it is re-classifed as 'Electric'. DVLA are happy with this, but then refuse to apply the same criteria and logic to the later cars. Likewise they claimed that the definition of 'Electric' was "only from first registration", yet again, there is NO SUCH stipulation within the regs. They are making stuff up just to maintain their current position.

I think this is all unacceptable. Legal opinion is that they are wrong and even morally, they should accept this and modify their attitude as the more vehicles are converted, the better for the environment - something the government is so keen to promote they have made the sale of ICE cars illegal after 2035 (and that may be brought forward to 2030). So the DVLA are acting not only incorrectly according to the law, but against the apparent will of the government. They need to be forcefully challenged on this.

I have reached the end of direct negotiations with the DVLA. They are intransigent and will not budge, so convinced are they of their rightful interpretation of the regulations. So this needs to be taken further. At this stage, I'm just not sure where though. I think my local MP is about to get his ears bent over this, but ultimately it needs to go higher. It is the Chancellor of the Exchequer who sets these rules. Anyone know him?


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## Emyr (Oct 27, 2016)

eUKenGB said:


> At this stage, I'm just not sure where though. I think my local MP is about to get his ears bent over this, but ultimately it needs to go higher. It is the Chancellor of the Exchequer who sets these rules. Anyone know him?


Baroness Worthington introduced this bill which got its first reading on January 23rd 2020:








Electric Vehicle Trading Scheme and Road Usage Duty (Consultation) Bill [HL] - Parliamentary Bills - UK Parliament


Current version of Electric Vehicle Trading Scheme and Road Usage Duty (Consultation) Bill [HL] with latest news, sponsors, and progress through Houses




services.parliament.uk





Last line of the summary:
*and to provide for graduated rates of duty to apply to modified vehicles. *


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## eUKenGB (Feb 21, 2019)

Sounds hopeful as the current VED charging scheme is a total mess, with some vehicles able to drive HUGE mileages at no cost, while others still have to pay an exorbitant rate even if not used. I had always previously campaigned to add the equivalent of VED (road tax) onto fuel as that totally solved the problem. Those who made the most use of the roads and caused the most wear and tear had to pay the most. But then EVs came along which relegated that idea to the scrap heap.

I did however read a tongue-in-cheek suggestion by someone (not me, I forgot now who) to scrap VED and put an equivalent on TYRES.

I know, sounds daft, but think about it. It serves the same function as on fuel, but also deals with EVs. It is actually a rather brilliant suggestion and ultimately so very simple. Which of course means the government would never adopt it, preferring instead some convoluted and indecipherable scheme that wouldn't actually achieve what they say they are trying to achieve.

That aside, there HAS to be a change some time in the future as the government make such enormous revenue from VED and they would NEVER allow that to diminish due to the increasing percentage of EVs on the roads. But I would support any FAIR system that actually charges more from those who use the roads more. If that means converted cars have to pay, I have no objection, as long as they have to pay what is appropriate for an electric car doing that number of miles. The current situation of a converted car first registered 28 Feb 2001 car paying £0 VED, while the same model that happens to have been registered 1 Mar 2001 ( i.e. next day) has to continue paying the full 'petrol rate' (possibly £600 p.a.) is nonsensical. Being less polite, stupid.

But it's not happening fast. It'll take the government years to come up with another idiotic scheme. We'll see. In the meantime, we just need to have DVLA told to correctly re-interpret the law.


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## boatman (Apr 13, 2012)

Not sure if this is useful at all, or a correct interpretation of the DVLA's position, but has anyone pointed out that their argument would allow people to put big V8s into originally small, low CO2 vehicles, and not pay any more!


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## eUKenGB (Feb 21, 2019)

boatman said:


> Not sure if this is useful at all, or a correct interpretation of the DVLA's position, but has anyone pointed out that their argument would allow people to put big V8s into originally small, low CO2 vehicles, and not pay any more!


Absolutely, a very relevant question. I seem to recall reading somewhere that having just stated no change to CO2 was allowed (in response to enquiry re. electric conversion), DVLA were asked this exact question and replied that in that case they would certainly charge more, according to the new engine and saw no double standards in this.

I would like to say they did definitely say this, but I cannot verify as I cannot remember where I might have read that. It does though sound like something DVLA would say.

It occurs to me that not only do I want DVLA to change their 'ruling' for 2001-2017 cars converted to electric, but I also think the government should support electric conversions with grants and/or other subsidies to positively encourage the replacement of ICE with electric power. Why not. There are a huge number of cars that fall into this category, enough to make a significant impact on overall vehicular emissions, if conversion was a financially practical proposition. This entire sector is being ignored, discouraged even from attempting it. If they really want to help the planet, they should actively encourage conversion to electric for ANY car, whatever the age.


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## bigpie (Dec 14, 2017)

Anyone managed to update a post 2001 yet? I've been having a back and forth with the DVLA refusing to even update my V5 fuel type let alone tax.

I've been collecting information and have come across a plate that's showing as electric and 0g/km and the owner has said they don't have to pay tax anymore. If anyone has any other post 2001 plates it might help to the argument.


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## MoonUnit (Jun 29, 2019)

I'm still waiting for DVLA to agree my '71 Beetle has been converted. It's been 6 months so far and they've even sent an inspector to make sure I'm not hiding a petrol engine in there somewhere. 

But to the point for post 2001 cars, it looks like DVLA seem to be referring to Schedule 1, Part 1A, Paragraph 1A, Sub-paragraph(5). The text is here:






Vehicle Excise and Registration Act 1994


An Act to consolidate the enactments relating to vehicle excise duty and the registration of vehicles.




www.legislation.gov.uk





This schedule deals with change in _tax_ rate, NOT change in _fuel_ type. Unless there is something else in the legislation that prevents change in fuel type, DVLA should be able to register the change to electric (which would allow for correct MOT). But, the way the sub-para is worded, it does look like the DVLA can't change the _tax_ band (which is clearly madness).

That schedule is silent on changing fuel type, and I think DVLA could be challenged on that first - it does lead to a schitzoid scenario with a car changed to electric fuel type but with a ('unchangeable') CO2 emissions rating and non-zero tax band. I think if the first part can be done (agreed change to electric) then the second part (tax band change) can be done over time. It looks like it would need an amendment to to the legislation to correct it.

@eUKenGB suggests he has seen legal advice saying DVLA's interpretation is wrong - can you post more info on this please?

Can anyone point to a reference in the legislation that prevents a change in fuel type? AFAIK it's possible to change a post 2001 car to LPG, for example?


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## bigpie (Dec 14, 2017)

That is indeed what they are referring to, again I've pointed out that it doesn't state they cannot change the fuel type, once changed 20G should kick in. Vehicle Excise and Registration Act 1994

Check out my blog post. DVLA Refusal to Update V5

01792 782818 is direct line to Kits & rebuilds if you wanted to call the office direct.









Sign the Petition


Recognition for Electric Vehicle Conversions




www.change.org


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## SimonRafferty (Apr 13, 2009)

I just had a chat with a nice chap at DVLA regarding my conversion. Mine is a 2021 Vehicle (with all the complicated CANBUS bits). Although late conversions are unusual at the moment, I thought it might be useful to people going forward.

The guy said I just needed to provide a log / report of the conversion with a covering letter plus the V5 document. So long as the report indicates it is genuinely an electric vehicle, they will change the fuel type and registration class (presumably to zero). There wasn't any drama - and it felt like he dealt with this every day!

Insurance (through Adrian Flux) was similarly easy - they just issued a policy!


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## favguy (May 2, 2008)

SimonRafferty said:


> I just had a chat with a nice chap at DVLA regarding my conversion. Mine is a 2021 Vehicle (with all the complicated CANBUS bits). Although late conversions are unusual at the moment, I thought it might be useful to people going forward.
> 
> The guy said I just needed to provide a log / report of the conversion with a covering letter plus the V5 document. So long as the report indicates it is genuinely an electric vehicle, they will change the fuel type and registration class (presumably to zero). There wasn't any drama - and it felt like he dealt with this every day!
> 
> Insurance (through Adrian Flux) was similarly easy - they just issued a policy!


Good news, interested to know what you've converted?


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