See our new article for the latest issues with DVLA reclassifying vehicles as motor caravans
Although the term motorhome is very widely used, it is not officially recognised in the UK as a vehicle type. The legislative term used in the UK is motor caravan.
Under the European Community Whole Vehicle Type Approval (ECWVTA) scheme a motor caravan is defined in the Individual Vehicle Approval (IVA) Manual for Vehicle Category M1 (Passenger Vehicles) as follows:
A special purpose M1 category vehicle (vehicle having 8 or less passenger seats) constructed to include living accommodation which contains at least the following equipment:
- seats and table,
- sleeping accommodation which may be converted from the seats,
- cooking facilities, and
- storage facilities.
This equipment shall be rigidly fixed to the living compartment. The interpretation applied to this definition is as follows:
Seats and a Table
• Are required to be an integral part of the living accommodation area, and mounted independently of other items.
• The table must be capable of being mounted directly to the vehicle floor and/or side wall.
• The table mounting arrangement must be secured as a permanent feature, (bolted, riveted, screwed or welded), although the table may be detachable.
• Permanently secured seating must be available for use at the table.
• The seats must be secured directly to the vehicle floor and/or side wall.
• The seats must be secured as a permanent feature, (bolted riveted, screwed or welded).
• Must be an integral part of the living accommodation area.
• Either beds or a bed converted from seats (to form a mattress base)
• Secured as a permanent feature, with base structures bolted, riveted, screwed or welded to the vehicle floor and/or side wall, (unless the sleeping accommodation is provided as a provision over the driver’s cab compartment.
• That are an integral part of the vehicle living accommodation and is mounted independently of other items.
• That are secured to the vehicle floor and/or side wall.
• Secured as a permanent feature, (bolted, riveted, screwed, or welded.
• The cooking facility must consist of a minimum of a two ring cooking facility or a microwave in either case having a fuel/power source.
• If the cooking facility is fueled by gas having a remote fuel supply, the fuel supply pipe must be permanently secured to the vehicle structure.
• If the cooking facility is fueled by gas having a remote fuel supply, the fuel reservoir must be secured in a storage cupboard or the reservoir secured to the vehicle structure.
• Storage facilities must be provided by a cupboard or locker.
• The facility must be an integral part of the vehicle living accommodation, ie mounted independently of other items, unless incorporated below seat/sleeping accommodation or the cooking facility.
• The storage facility must be a permanent feature, (bolted, riveted, screwed or welded).
• The storage facility must be secured directly to the vehicle floor and/or side wall, unless a storage provision is provided over the driver’s cab compartment.
The above requirements apply to new vehicles.
For conversions, or the import and registration, of existing vehicles the DVLA has to make an assessment as to whether the construction of the vehicle meets the criteria required to justify registering it as a motor caravan.
VOSA have produced guidance document to assist in this assessment:
DVLA revised their rules on campervan conversions in 2011
It used to be the case that anyone who converted a commercial vehicle to a motorhome or campervan could apply to the DVLA for the 'body type' classification on the V5C Registration Document to be changed to 'motor caravan'. However we heard that recent requests to change the body type classification were being refused by DVLA.
We asked them what new criteria were being applied, this is the response we received:
When describing the external appearance of a vehicle DVLA applies a 'reasonableness test' which is based on how a member of the public or police would describe the vehicle in traffic or if parked on the road. This is a longstanding procedure. Whilst vehicles kept or used on public roads in Great Britain must meet both domestic and European regulations such as Type Approval, DVLA body type descriptions are a separate entity to approval requirements.
However, as DVLA have recently seen an increase in the number of applications to change the body type description on the vehicle registration document (V5C) to motor caravan, we reviewed the body type description 'motor caravan' in conjunction with the police and the ABI.
There was a clear consensus that the body type should reflect the outward appearance of a vehicle rather than its internal fixtures and fittings. As a result only vehicles first registered as motor caravans or those fitted with a custom coach built bodies, in addition to meeting the internal 'checklist' should be described as 'motor caravan' on the V5C.
We are aware that some motorists have complained that insurance premiums can be higher if the body type for converted vehicles does not show motor caravan. However the ABI have advised that insurance premiums would normally be calculated based on the information provided by the customer. They further advised that customers should make their insurers aware of any modifications made to the vehicle and this would be taken into account when the premium is calculated.
This seemed to us to represent a very narrow interpretation of the term 'motor caravan' and appeared to impose much stricter requirements than those required by EU Type Approval legislation. Taken at face value it seemed to mean that NO conversions of any type of vehicle that has been previously registered will be able to re-register with a change of body type to motor caravan (unless they have had a coachbuilt body fitted), even bone-fide professional conversions that any reasonable person would consider to be a motor caravan.
It had implications for speed limits, since the term 'motor caravan' is used to determine that passenger vehicle, rather than goods vehicle, speed limits apply. MOT tests are another potential problem area where the type of test which is applicable may be affected if a vehicle is not described as a motor caravan on the V5C. For vehicles over 3500kg GVW it is possible that the regulations relating to drivers hours and the fittment of speed limiters and tachographs may also apply if the vehicle is not described as a motor caravan on the V5C.
We now hear that, following many complaints about the new policy, they have re-examined the issue. We asked for an explanation of the revised policy and received the following:
Apologies for the delay in replying we have been further reviewing our policy around the allocation of body type descriptions for motorcaravans taking into account the views of customers/key stakeholders like yourself. Recognising the impact the policy may have on professional converters and our customers who self build I am pleased to inform you that following a further review the policy will allow greater flexibility for vehicles which have been modified both internally and externally from the manufacturers original specification after first registration and consideration will be given to conversions which have been carried out professionally where the customer can provide documentary evidence from the converter or a self build conversion where the customer can provide documentary evidence of the build.
In addition to documentary evidence customers will still be required to provide external and internal photographic evidence of the conversion/build and also return their V5C for amendment. As previously advised cases can vary significantly and DVLA deals with each case individually, based on the photographic and documentary evidence provided by the customer/registered keeper. DVLA will continue to consider applications requesting a change of body type description but we will need to consider both the internal and external appearance of a vehicle. I should advise you that conversions will still be required to meet the internal criteria required for a motorhome/motorcaravan but greater flexibility will be applied to the external appearance of a vehicle.
We submitted photos of a panel van, which had been converted some years after it's original registration, to them for appraisal. Under the 'original' revised policy, as far as we can tell, it would have been classed as a 'van with windows', now they have confirmed that it would be classified as a 'motor caravan'.
It seems to us that there should now be no difficulty in registering a conversion as a motor caravan, providing that the conversion meets the 'reasonableness test' and that the exterior has been modified by at least having windows fitted.
UPDATE August 2019
The DVLA have now reverted to their 2011 'rules' on changing the Body type to motor caravan after conversion.
Despite several Freedom of Information requests they have so far been unable, or unwilling, to provide any sort of guidance on the criteria they use to determine whether to approve a change of body type.
See this page for a separate article on the issue.