Registering and changing tax class of an EV conversion in the UK

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Re: Registering and changing tax class of an EV conversion in the UK

Post by Maker_of_Things »

Kevin Sharpe wrote: Sun Jun 21, 2020 6:28 pm
Peter wrote: Sun Jun 21, 2020 3:04 pm I have converted a car from ICE to Electrickery and now fully legal on the road.
When was the car first registered?
Which way does the age of the car work in this, and what's the cut off date/age? If anyone knows from legislation.

Just so others can see if choosing an older conversion, or a younger conversion would be easier, until something more sensible is resolved.

Thank you.
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Re: Registering and changing tax class of an EV conversion in the UK

Post by SciroccoEV »

There is some confusion over this. What can't be changed is a vehicles official CO2 rating, but it seems it can have it's fuel type changed to electric. TFL have allowed motorcycles to be emissions tested to see if they meet the LEZ requirements, even though they're only factory rated for the previous standard.

Not long ago, I sold an old Prestolite series wound motor, complete with suitable adaptor plate, to a local VW Beetle owner. He followed the procedure I suggested, MOT, letter from a garage saying they'd fitted the motor and send the V5C off to the DVLA with a bunch of supporting pictures. An amended V5C came back within a few weeks.

The requirement for a company to have carried out the conversion work is erroneous. I established this at the Luton DVLA office shortly before they were all shut. It stemmed from the fact that you could do an LPG conversion and and then apply for a reduced road tax class, but the conversion had to be carried out by an approved installer and using an approved kit. When asked for an invoice from the conversion company, I just asked for a sheet of paper and said I'd write one. They then tried to tell me it needed to be a VAT registered business, so I asked to see the relevant legislation and ended up talking to the office manager. He could find no such requirement, either for it to be a VAT registered company, or even to have been a professional conversion. The DVLA still seem to ask for the conversion invoice, but just asking a helpful garage to provide one seems to do the job.
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Re: Registering and changing tax class of an EV conversion in the UK

Post by Maker_of_Things »

That'a useful to know.
For the time being I am less fussed about the VED based on CO2 as it won't directly affect me in the foreseeable future, and having to pay it won't stop me learning how to make my conversion work.
But worth looking into further for the next time.

I am going to aim for doing this simple approach until such time something makes me need to reconsider.

I watch with interest and will see what else I can find out.
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Re: Registering and changing tax class of an EV conversion in the UK

Post by eUKenGB »

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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Re: Registering and changing tax class of an EV conversion in the UK

Post by bobby_come_lately »

I can't say I know Rishi but I think if you were to post your letter to your MP as a template, quite a few of us would be willing to copy it and send it to our representatives? Seems like something that would be very in line with their idea of a post-Brexit spirit of British innovation (ahem).
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Re: Registering and changing tax class of an EV conversion in the UK

Post by eUKenGB »

Certainly an example of British democracy at work. It's would be a good idea to create a letter template as I am well aware that apathy would otherwise mean very few letters would actually get sent.

I'll try and put something together with input from anyone else who wishes to assist.
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Re: Registering and changing tax class of an EV conversion in the UK

Post by bobby_come_lately »

Happy to help. Don't know much about law or politics but I'm decent with words.

I'll also loop in the EVA who I contacted earlier in the thread and ask for their support.
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Re: Registering and changing tax class of an EV conversion in the UK

Post by Kevin Sharpe »

bobby_come_lately wrote: Thu Sep 03, 2020 7:47 pm Happy to help. Don't know much about law or politics but I'm decent with words.

I'll also loop in the EVA who I contacted earlier in the thread and ask for their support.
It's critical you folks get organised and take on this fight... you do not want a restrictive environment like we have in The Netherlands imposed on you :shock:

Has anyone contacted Bryony Worthington? What about vendors like Zero EV and Electric Classic Cars?
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Re: Registering and changing tax class of an EV conversion in the UK

Post by bobby_come_lately »

Right, I've drafted a letter to kick things off. Have opened it up to comments rather than edits. Take a look and if you're interested in campaigning for this, let me know what you think:

https://docs.google.com/document/d/11zu ... sp=sharing
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Re: Registering and changing tax class of an EV conversion in the UK

Post by Kevin Sharpe »

bobby_come_lately wrote: Fri Sep 04, 2020 6:41 am Right, I've drafted a letter to kick things off.
Great initiative... good luck!
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Re: Registering and changing tax class of an EV conversion in the UK

Post by 4markowen »

Rishi would certainly be interested in the duty, but there's also the transport minister (Shapps) and environment minister (Eustace) to consider too. Perhaps targeting Labour Shadow minsters first to get the issue raised, get their attention and their help in shaping a larger campaign? Perhaps less broadly targeting all MPs just yet and finding a single champion?

Usual problem with politicians though, what's in it for them? Trouble is EV conversion is taking cars into a free tax bracket. Even if the previous car has had years of previous contributions. Perhaps shaping it as an upskilling / cross skilling of existing business to EV; Businesses that pay rates, employee NI contributions and tax? Obvious CO2 savings?
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Re: Registering and changing tax class of an EV conversion in the UK

Post by LRBen »

bobby_come_lately wrote: Fri Sep 04, 2020 6:41 am Right, I've drafted a letter to kick things off. Have opened it up to comments rather than edits. Take a look and if you're interested in campaigning for this, let me know what you think:
Looks great. I have emailed my two Local MPs down here in Somerset using a personalised opener and then that letter as a uniform viewpoint.

Just a note for others sending emails to your MP. Make sure you include your full name and address and make it obvious from the start that you are constituent.
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Re: Registering and changing tax class of an EV conversion in the UK

Post by bobby_come_lately »

Brilliant. Good points.
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Re: Registering and changing tax class of an EV conversion in the UK

Post by bobby_come_lately »

Right, my letter to my MP (Afzal Khan, Labour) is going today and I'm sending an edited version to Baroness Worthington as well.
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Re: Registering and changing tax class of an EV conversion in the UK

Post by Bigpie »

Reply from John Healey MP (Labour)
"
Thank you for your email. I appreciate the concerns you raise surrounding the legal process of converting your car’s engine into an electric or hybrid engine. Phasing out fossil fuel powered cars is absolutely essential if we as a country, and as a planet, wish to tackle the ongoing climate emergency which we all are facing as a species.

Labour has promised to implement a ban on the sale of fossil fuel powered cars by 2030 – an ambitious but achievable goal. Labour promised in the last election to invest £3.6 billion in expanding the UK’s electric vehicle charging infrastructure. However, it does not escape policy makers that such a transition will place a burden on the lowest incomes, who bear the burden of pollution from cars. Labour has pledged to offer 2.5 million interest free loans of up to £33,000 to low income households to purchase electric cars.

Yet, you raise an important point that if the rules can be simplified and consistently applied in the area of electric vehicle conversion, allowing private individuals and garages to convert and swap fossil fuel engines into electric vehicle engines, this could also be another route to achieving the electric vehicle revolution this country so greatly needs if we wish to tackle the ongoing climate emergency. As a result, I do think this could be something worthy of consideration at a policy level and I will speak to the relevant Shadow Ministers about this issue.

With best wishes
John
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Re: Registering and changing tax class of an EV conversion in the UK

Post by bobby_come_lately »

Marvellous. A great start. Could anyone else who has had a response post it here?
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Re: Registering and changing tax class of an EV conversion in the UK

Post by Boxster EV »

I forgot that I started this thread at the beginning of the year. Therefore, in the spirit of transparency of where I am with the formal registration document confirming the changes, here’s an update:

I wrote to the DVLA on the 20th February providing the following:

• The car’s existing V5C
• V627/1 Built up vehicle report
• Receipt for the purchase of the electric motor and batteries
• Information regarding the commercially available kit and garage that supported the build
• Photographs of the car demonstrating the build
• I also completed a V55/C although I’m not sure if this was necessary

They wrote back to me on the 17th March and told me the following was required for them to process the conversion:

1. The car must have a valid MOT to apply for a change in tax class and fuel type
2. The car must be taxed (as a petrol car). It was SORN at the time
3. I must provide a letter from the company that completed the conversion
They then reissued me with a new V5c, identical to the one I’d just sent them. :x

All three of these requests were somewhat daft for obvious reasons. Even the third point is no guarantee that the conversion has been completed in a safe and professional manner. Other than the MOT, there’s no specific inspection relative to the conversion (due to a change of just two major components according to DVLA logic).

Anyway, I got the car MOT’d by our local garage on the 1st May (it was delayed due to covid). The inspector even confirmed that the system allowed the fuel type to be input as “ELECTRICITY” on the system. The car passed and I had an MOT certificate confirming the car was roadworthy and that the fuel type was electric. Happy days..... or so I thought.

*Note that the DVLA shut down almost entirely from March through to June.

On the 3rd May, upon being in possession of a valid MOT certificate, I taxed the car immediately and wrote back to the DVLA. I included a letter from the garage that built the LDU mounting kit and supported the build.

I called the DVLA on the 19th August for an update. After being on hold for nearly 40 minutes, I was told that the relevant department has all of the information they need to process the application, however they were running approximately 8 weeks behind. No problem I thought, I’ll wait.

Today is the 1st October and I am yet to hear anything. I called again this morning – things must be improving as it only took 10 minutes to answer the phone this time (after spending 5 minutes navigating their automated phone menu). The advisor told me that nothing had changed since my last call and that she didn’t even have the means to speak to the relevant department. She offered to send an internal communication to them and ask for a response.

So, I’m presently in limbo. Driving an electric car but taxing it as an ICE. The £25 a month road tax is chipping away at me. :(

I’ve kept the insurance company informed and they don’t seem bothered by the DVLA bureaucracy and advised in writing that I’m still covered comprehensively.

I've made a note to call the DVLA again in a week's time. :)
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Re: Registering and changing tax class of an EV conversion in the UK

Post by eUKenGB »

Sums up DVLA doesn't it. Before they will change taxation class to one exempt from VED, you have to pay the VED.

Maybe not so daft. At the very least they will get a month's VED out of you and the more they faff about and delay registering the change, the more they get before allowing you to not pay any more.

As a 986 I presume it was first registered before April 2001, prior to emissions based VED ?
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Re: Registering and changing tax class of an EV conversion in the UK

Post by Boxster EV »

eUKenGB wrote: Thu Oct 01, 2020 5:18 pm Sums up DVLA doesn't it. Before they will change taxation class to one exempt from VED, you have to pay the VED.

Maybe not so daft. At the very least they will get a month's VED out of you and the more they faff about and delay registering the change, the more they get before allowing you to not pay any more.

As a 986 I presume it was first registered before April 2001, prior to emissions based VED ?
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Re: Registering and changing tax class of an EV conversion in the UK

Post by DenkiJidousha »

There is also the EVA Scotland as a possible lobbying group https://www.eva.scot/

As a member I had a quick search on their forums but didn’t see anything relevant to conversions. Maybe I should post and ask, or email.

The current situation makes me reluctant to seriously entertain doing a DIY conversion... tempting as it is.
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Re: Registering and changing tax class of an EV conversion in the UK

Post by DenkiJidousha »

bobby_come_lately wrote: Fri Sep 04, 2020 6:41 am Right, I've drafted a letter to kick things off. Have opened it up to comments rather than edits. Take a look and if you're interested in campaigning for this, let me know what you think:

https://docs.google.com/document/d/11zu ... sp=sharing
May I share that link on the EVA Scotland member's forum, with a link back to this thread too?
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Re: Registering and changing tax class of an EV conversion in the UK

Post by DenkiJidousha »

Another idea, if you have the ear of your local EV garage, get them to email the MP too. And perhaps HEVRA (Hybrid and Electric Vehicle Repair Alliance Ltd.) might back this too? https://www.hevra.org.uk/
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Re: Registering and changing tax class of an EV conversion in the UK

Post by bobby_come_lately »

DenkiJidousha wrote: Thu Oct 08, 2020 2:36 pm
bobby_come_lately wrote: Fri Sep 04, 2020 6:41 am Right, I've drafted a letter to kick things off. Have opened it up to comments rather than edits. Take a look and if you're interested in campaigning for this, let me know what you think:

https://docs.google.com/document/d/11zu ... sp=sharing
May I share that link on the EVA Scotland member's forum, with a link back to this thread too?
By all means! Share it far and wide.

*still* waiting for a response here though.
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Re: Registering and changing tax class of an EV conversion in the UK

Post by DenkiJidousha »

Shared, but the EVA Scotland forums are very quiet. I might be better off emailing their leadership...
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Re: Registering and changing tax class of an EV conversion in the UK

Post by njel13 »

Posted on the EVA Scotland site and forums. We've tweaked the letter slightly,
_______________________________________________________________________________________________________________________________
Please personalise for your MP****

Dear Mr/Mrs/Ms/Miss/Mx/Misc/Ind

I am writing to you as part of the Electric Vehicle Community.

One of the biggest barriers to getting more electric vehicles on the road at an affordable price is inconsistently applied regulation. I would like your support in getting clarification of these regulations so that professional garages and competent individuals can safely convert existing petrol and diesel vehicles into electric cars. This will be good for our economy, and good for the environment.

It is now possible to convert a petrol or diesel car to electric for less than £3000 using parts recovered from written-off electric and hybrid vehicles. These parts are extensively tested and used in hundreds of thousands of vehicles around the world. The process is relatively simple and can be completed by any competent home mechanic or garage. In most respects it differs little from any other engine swap - a common process in car maintenance.

The possibilities this creates for innovation and environmental savings are enormous. But today many enthusiasts are dissuaded from taking on projects because of inconsistent regulation. The rules from the DVLA are, in the experience of members of the EV conversion community unnecessarily complicated, poorly communicated, and inconsistently applied.

A simple clarification of the rules that says that any car of any year can be converted to electric power by a private individual or garage and be certified for the road with a simple MOT, as long as the vehicle does not have significant structural modifications would make a huge difference. Simply put, a motor swap to electric should be treated just like any other engine swap.

Once converted, a car should be able to receive the appropriate duty classification as an electric vehicle, for the purposes of vehicle tax and low emissions zones. We believe that this is legally the case already, under the 1994 Vehicle Excise and Registration Act, but this will be confirmed by Baroness Worthington’s private member’s bill (Electric Vehicle Trading Scheme and Road Usage Duty (Consultation) Bill [HL] 2019-21), currently awaiting its second reading in the House of Lords.

Some of the members of the community have successfully tested and registered their converted cars as electric without issue. While others with similar projects have run into trouble. We don’t believe we are asking for any changes to legislation, merely clarity of communication and consistency of application of the existing rules in a way that supports innovation, entrepreneurship, and the reduction of the carbon footprint of our vehicles.

Conversion of combustion vehicles to EVs offers some key advantages, with cost and embodied carbon most notable. Simplifying this process has the potential to support not only action on climate change, but also help with small businesses and job creation.

If you would be willing to support this, would you be able to add your name to a letter requesting this clarification that will be going to the chief executive of the DVLA, the Department for Transport, and the Treasury from the OpenInverter Forum. Please let me know if you would be happy to support this campaign for more innovative and sustainable transport in the UK.

Yours Sincerely,

Your Name
Your Address

_______________________________________________________________________________________________________________________________
Neil
EVA Scotland

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