UK(NI) Type Approval Scheme – Frequently Asked Questions

Updated guidance for manufacturers, importers and distributors working with vehicle approvals, statutory markings, VIN plates and compliance requirements in the United Kingdom.

Last updated: July 2024

Summary

The UK(NI) Type Approval Scheme has applied since 1 January 2021 and is one of the routes for registering vehicles in the United Kingdom. This guide explains how retained e11 approvals, UK(NI) approvals, GB approvals, statutory vehicle markings, Certificate of Conformity requirements and UK(NI) labels work in practice.

What is a retained e11 approval?

If an e11 type approval was not transferred to an EU member state before 1 January 2021, it was automatically treated as a UK(NI) approval. This means the approval can still support products placed on the market in the UK, but it no longer allows those same products to be sold into the European Union under that approval.

Retained e11 approvals may appear in formats such as:

• e11*2007/46*XXXX
• e11*NKS*XXXX
• e11*KS07/46*XXXX
• e11*KS18/858*XXXXX
• e11*NKS18/858*XXXXX

What can you do with a retained e11 approval?

Businesses holding a retained e11 approval have more than one route available depending on where they intend to sell vehicles or components.

Keep it as a UK(NI) approval

If you want to retain the approval under the UK(NI) scheme, no immediate action is required. At the next extension, the approval will be updated to show that it now follows UK(NI) requirements. This may result in a revised approval number using the n11 format.

As a transitional measure, the earlier e11 approval number could continue to appear on statutory markings until 1 January 2023, provided that the e11 marking represented a UK(NI) approval rather than an EU approval.

Reclassify it as a GB approval

If you want the approval to operate under the Great Britain scheme, you should contact your usual VCA contact and request reclassification. This is handled as an internal VCA amendment. At the next extension, the approval will be revised to reflect GB requirements and a new g11 approval number will be issued.

The new GB approval number will be different from the previous e11 reference because it is issued using the next available sequential number.

Hold both UK(NI) and GB approvals

It is also possible to hold both a UK(NI) approval and a GB approval for the same type. For example, an existing e11*NKS*XXXX approval could remain in place as a UK(NI) approval while a matching g11*NKS*XXXX approval is created for Great Britain. This is treated as a continuation of an existing type rather than a completely new type approval route.

What about EU Small Series approvals?

A retained e11 approval that previously operated as an EU Small Series approval using KS approval characters will now be regarded as a UK(NI) EU Small Series approval.

If required, it can also be converted into the GB equivalent, known as a GB Medium Series approval, using the same logic and production threshold of up to 1,500 units. This is still treated as a continuation of the existing approval rather than a brand-new type.

When do you need to decide?

If you want a retained e11 approval to be treated as a GB approval, it is best to contact the VCA as soon as possible. You should also ensure that the correct representative is in place for the approval type you intend to hold. If no change is needed, no action is usually required until the next planned extension.

What is the difference between UK(NI) approval and GB approval?

UK(NI) approval

A UK(NI) approval is valid in Northern Ireland and is also currently accepted in Great Britain. These approvals continue to follow EU rules, which means manufacturers must have a representative located in either the EU or Northern Ireland unless they are already based there themselves.

Since 1 January 2022, this representative requirement has been checked when approvals are revised or extended and during Conformity of Production (CoP) audits.

A new or extended UK(NI) approval may appear in a format such as n11*2007/46*XXXX.

GB approval

The GB Type Approval Scheme is the approval route for Great Britain. It replaced the provisional GB framework and is based on retained EU legislation as it applied in GB at the end of 2020.

If you do not plan to sell in Northern Ireland, or if you do not have a suitable representative based there, a GB approval may be the more suitable route. A GB Whole Vehicle Type Approval does not have the 4 metre height restriction, and the GB National Small Series route also has its own numerical limits.

A new or revised GB approval may appear in a format such as g11*2007/46*XXXX. Approval holders must have a representative based in Great Britain if they are not already established there.

Who can act as the representative?

The representative may be the approval holder if they are based in the correct jurisdiction, or it may be a separate third-party representative. Where a third party acts in this role, their obligations are set out in Article 15 of EU Regulation 2018/858 as retained in UK law.

Can you hold multiple approvals?

Yes. A manufacturer can hold both UK(NI) and GB approvals for the same type. It is also possible to hold a European Whole Vehicle Type Approval from the EU or UK(NI) alongside a UK(NI) Small Series approval. The same principle applies in Great Britain, where a GB Whole Vehicle Type Approval can exist alongside a GB Small Series approval.

How does Northern Ireland unfettered access affect you?

A qualifying Northern Ireland good may be imported into Great Britain using an EU approval without additional approval requirements. In these situations, if the manufacturer does not have a presence in Great Britain, the importer takes on the legal responsibility for the product.

Does this affect Conformity of Production (CoP)?

Yes. Manufacturers will need to update their Conformity of Production clearance scope in line with the approvals they choose to maintain. They must also ensure that a suitable representative exists in the correct jurisdiction for each type of approval held.

What records need to be kept?

Where manufacturers operate with a combination of GB and UK(NI) vehicles, they must maintain clear records of VIN numbers and production volumes allocated to each market. This is especially important where small series approvals apply and production limits need to be monitored accurately.

Certificate of Conformity (CoC) and vehicle markings

If you hold an n11, g11 or retained e11 approval that has not been transferred to another EU approval authority, the approval number should appear on the relevant Certificate of Conformity (CoC) and be shown on the vehicle itself.

The statutory VIN plate should carry the same approval number. Since 1 January 2022, this has been checked during approval extensions and CoP audits.

Before that date, manufacturers could continue issuing the EU CoC and using the e11 approval number on the VIN plate, provided records were kept linking each VIN to the correct approval route, whether UK(NI) or GB.

If the original e11 approval was transferred to another EU Type Approval Authority following the UK’s departure from the EU, that old approval number no longer exists and products should not continue to be marked with e11.

Do you need to use the UK(NI) label?

Manufacturers using retained e11 approvals or n11 UK(NI) approvals for full series or EU Small Series (KS) products must place a UK(NI) label next to the statutory markings if they intend to place the product on the market in Northern Ireland.

This extra UK(NI) label is not required where the vehicle or product is using a UK(NI) national small series approval number (NKS).