EReg Topic Group IV Harmonisation of commercial and temporary plates

1. ERegTopic Group IVHarmonisation of commercial and temporary plates Progress Report LAMESCH Jean

2. Introduction Initiative to solve the problems on cross border trade of vehicles started by the Commission in 2004 by Mr Willy MAES and Mr Hans INGELS. The results of theirworkwasmostlyintegrated in the «Interpretative Communication» of the EU Commision on procedures for the registration of motorvehiclesoriginating in anotherMember State, dated 14.02.2007. - Cross Border vehicletradeencouragedunder the optic of free circulation of goods in the E.U. . - Problems are generated by the transfer of vehiclesfrom one EU Member state to another EU Member Stata and the possible crossborderpresentation of vehicles by dealers in other countries. LAMESCH Jean

3. Introduction For the purpose of cross border trade there exist mainly two types of registrations and plates: - Temporary registrations and plates, destined to private persons and allowing them to transfer a vehicle purchased in another country to their country of residence for the final registration. Professional registrations and plates, destined to vehicle retailers, distributors, repair or similar enterprises of the automotive sector These types of registrations exist in nearly all European countries. LAMESCH Jean

4. Analysis The topic group started by analysing the actual situation. The followingproblemswereidentified: - Mutual recognition of the ‘special’ registrations and the relating ‘special’ plates. - Identification of the validity of the registration by the enforcers. - Risk to becontrolledveryhigh due to unusual format of the plates. - Professional registrations and plates generally not accepted, due to lack of vehicle identification requiredaccording to the Vienna Convention and Directive 1999/37. - Taxproblems. - Reluctance of insurancecompanies to insurevehiclesunderthese registrations and difficulties to check validity of insurancecoverage. LAMESCH Jean

5. Analysis - Technical condition of the vehicledifficult to check. - Date of first registration of vehiclesused for a longer periodwithprofessional registrations difficult to determine. - No possibility of checks via national databases, nor by systemslike EUCARIS, as vehicleswithprofessional registrations are not identified. - Documents’ validity as difficult to identify for enforcers as the validity of the plates, and thismainly due to the numerousvariants in the different countries. LAMESCH Jean

6. Questionnaires - A first questionnaire was sent out to all EReg members. - Replies have been received from 23 countries, whereof a summary has been sent to all TG members. - A second questionnaire was sent out end September 2010 in order to get more details about the systems in place. - As to this second questionnaire, replies have been receivedfrom 17 countries. LAMESCH Jean

7. Present situation for temporary registrations - Of the 23 countries,2 have no temporary registration system. - 6 countries have more than one system. - 4 countries have no restrictions as to whom such registrations are made available. - In most countries availability of temporary registrations is restricted to non residents and for export only. - The maximum validity of the registrations varies between 1 day and unlimited. - 10 countries issue the same or similar registration documents to those issued for ‘normal’ registrations. - 1 country has two systems of temporary registrations but issues similar documents to their ‘normal’ registration documents for one type of plates only. LAMESCH Jean

8. Present situation for temporary registrations - To obtain a temporary registration all countries check the holder identification and insurance coverage. - In 10 countries a valid technical inspection certificate is required for used cars or temporary registrations are only issued for new vehicles. - 33 different designs of plates are issued either for professional or temporary plates. - Not only the validity of the temporary plates but also the pricesdiffersensibly. - 11 countries are not in favour of stickers LAMESCH Jean

9. Present situation for temporary registrations 6 countries use the same registration Certificate than the one for ‘normal’ registration: ▪ most countries estimate that they could introduce this document with reasonable efforts ▪ 1 country estimates this is totally impossible. - With the introduction of the normal Registration Certificate, EU Codification as in Directive 1999/37 seems to be possible in most countries. LAMESCH Jean

10. Present situation for professionnal registrations The situation is similar to that of the temporary registrations with 27 different systems identified. Detailswillbeavailable on the website of Ereg Main problemisthat, except in one country, a complete identification of the vehicleis not required. Some countries issue plates only but no documents. - Two multilateral agreements exist for the mutual recognition of commercial plates: ▪ Benelux agreement : Belgium - Netherlands - Luxembourg. ▪ Nordic agreement : Sweden - Norway - Finland - Denmark. LAMESCH Jean

11. General recommendations and aims The Topic Group has elaboratedrecommendations and aimscommon to bothsystems of registrations, as well as somethat are particular to one or the other system. General recommendations are: ▪ Bothsystemsshouldberecognisable and validthrough the whole of Europe, by aligningthem to existing or future legislation; thiswillremove the need of bilateralagreements. ▪ Documents shouldonlybeissued by the official registration authorities or mandated organisations, without information beingadded by the holder. LAMESCH Jean

12. Recommendations for temporary registrations Insurance proof mandatory Validityshould not exceed 45 days Holder of the registration must beidentified via an official ID Valid PTI document required Registration in ‘normal’ system and visible via systemslike EUCARIS LAMESCH Jean

13. Recommendations for commercial registrations Insurance proof mandatory Holder of the registration canonlybe a registered commercial party As valid PTI mightbedifficult to obtain, legislation must beadaptedthatvehiclecanonlybeused if itis road safe Main problemisthat in most of the systemsvehicleis not identified, therefore a logbookshouldbemandatory, minimum on paper, betterelectronicallowing the identification of the vehicle if used in international traffic Registration of the vehicledetails in ‘normal’ system and visible via systemslike EUCARIS LAMESCH Jean

14. Proposal Meeting of ERegmembers on the 10th of February 2012 with Mr Hans INGELS from the EU Commision in Brussels confirmedthatworkwasunderway on a new Regulation. Due to the Proposal for a Regulation of the EuropeanParliament and of the Council simplifying the transfer of motorvehiclesregistered in anotherMember State within the single Market, TG II and TG IV shallbemerged in one only TG in order to analyse and discussthisproposal LAMESCH Jean

15. Questions? LAMESCH Jean