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

[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.

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.

I called the DVLA again today. Still no progress and all incredibly frustrating.

The clerk had a similar script to the last one that I spoke to on the 1st October: "we're busy, covid means reduced staff, but I'll send a priority 1 request to the relevant department".

Nothing else they would do.

[bobby_come_lately]

So, I have had a fascinating response from my MP, who - fair play to him - passed my letter to the parliamentary undersecretary for transport who has responded at length.

Attaching the full letter here for you to read.

Key points:
"M1 and N1 type approved vehicles with a recorded CO2 emissions figure first registered on or after 1 March 2001 cannot move into an electric taxation class when the vehicle has been converted to an electric mode of propulsion."

This much we knew I guess

[pre-2001 vehicles (my interpretation)] "can have their taxation class changed to Electric Vehicle if the application to do so can be supported by evidence showing that the original engine and all ancillary parts have been removed. As a minimum, the accepted evidence must be either an itemised invoice of the work carried out, written confirmation on headed paper from the garage/converter detailing the work carried out or an inspection report provided for insurance purposes. If the application is accepted, the DVLA will amend the details on the V5C and update CAZ databases."

What counts as 'an inspection report for insurance purposes'? Does this mean, as I hope, that I can just get my garage to look it over and agree it's sound, rather than pretending to have done the work?

"At present, the MOT test does not assess whether electrical components (often of a high voltage) salvaged from vehicle write-offs are being used safely in vehicles. As such, there would be concern, for example, if components are being used that are not from the same system manufacturer."
Hmmm. I have a Prius inverter and a Mitsubishi motor...

"There are clear environmental and cost effective benefits to having an electric engine fitted to a vehicle but, at present, converting a vehicle to run on electric power is expensive, complicated and a risk to road safety if not carried out to correct standards."
I know what she's saying but I think we can dispel the 'expensive' part at least.

[AlexD]

To be fair shes not wrong in terms of the road safety aspect. Alot of builds have lithium batteries piled into the engine bay - If there was a bad enough collision it could turn bad pretty quick if any were damaged.

[bobby_come_lately]

To be fair shes not wrong in terms of the road safety aspect. Alot of builds have lithium batteries piled into the engine bay - If there was a bad enough collision it could turn bad pretty quick if any were damaged.

Oh there are definitely issues. That's my layout. But I don't know how that's much worse than a few gallons of petrol right behind the driver as my car is now. Albeit BMW has a slightly higher safety analysis budget than me...

[eUKenGB]

So, I have had a fascinating response from my MP, who - fair play to him - passed my letter to the parliamentary undersecretary for transport who has responded at length.

Attaching the full letter here for you to read.

Key points:
"M1 and N1 type approved vehicles with a recorded CO2 emissions figure first registered on or after 1 March 2001 cannot move into an electric taxation class when the vehicle has been converted to an electric mode of propulsion."

I dispute that and would respond with a request that they specify exactly what part of the regulations state that since as far as I (and other legal parties) are concerned the regulations do not state that at all.

This is the crux of the matter as DVLA (and other involved persons it would appear) are not correctly interpreting the regulations which state that the CO2 figure of the vehicles in question (first regd. between 2001 and 2017) cannot be changed, but it does not state that the Taxation Class cannot be changed. This is a purely made up restriction. I queried DVLA on this specific point and they were unable to indicate where this was stated in the regs, so it wasn't just me missing it when reading them through again and again.

In fact, the main provisions of the regs DO state that "electrically propelled vehicles are exempt from VED" and correct interpretation of that means that the schedule regarding emission rates and levels (that cannot be changed) does not need to be considered. The statement above does NOT include any other restrictions regarding dates of first regn. etc. It is quite clear, but DVLA are entrenched in their view and cannot accept they are in fact wrong.

Fact is that prior to 2001, VED was based on capacity. Change to electric and that parameter becomes irrelevant even if still shown on the V5C after re-classification (I've no idea whether it is or not). DVLA are quite happy about this. But post 2001 (and before 2017) they get their knickers in a twist about the rate Schedule saying CO2 emissions figure cannot be changed. So what. It becomes irrelevant once it has been converted to electric, which as I said is clearly stated in the main provisions as being exempt and if they want, that CO2 figure can remain on the V5C, it is simply not relevant once the Taxation Class has been changed to ELECTRIC and unless anyone can actually show me where it states otherwise, there is NO part of the regs that prevent the TC being changed.

British law is always open to interpretation, but in this case the regs are actually quite clear and DVLA are just determined to obfuscate the issue with their own invented restrictions. I have no idea why they are so determined about this since they are clearly in the wrong and sadly I suspect government officials will often just defer to DVLA's judgement on such matters (no doubt lacking the ability to read and understand the regs themselves). I suspect it needs a court case with a correct ruling by a judge to force DVLA to accept that the law actually does NOT prevent 2001 - 2017 cars being converted to ELECTRIC Taxation Class and hence subject to the applicable rate of VED - currently exempt.

I do not believe this is a matter of the law as what it actually states is quite clear. It is a question of making those in charge understand and apply it correctly. In the current state of global demand for reduced pollution, it HAS to be seen as the right thing to do. Not just grudgingly accept that is what the law states, but even to actively encourage such conversions. The question remains, how are we to do this?

[eUKenGB]

Another quick point about safety. DVLA are happy to accept pre 2001 cars being converted and re-classifying them as ELECTRIC. Sometimes without any inspection. So there's no reason why post 2001 cars should be treated any differently in this respect.

I'm not advocating inspection as that just adds more layers of what I consider to be unnecessary bureaucracy, I'm just saying that pre and post 2001 cars should be treated the same and conversions no different from swapping IC engines. Petrol is a fearsomely dangerous liquid, but familiarity has bred acceptance and a diminished understanding of the risks. OTOH, many see batteries as new and to be feared.

I don't see the safety of converted cars to be any issue at all.

[johnfin]

What counts as 'an inspection report for insurance purposes'? Does this mean, as I hope, that I can just get my garage to look it over and agree it's sound, rather than pretending to have done the work?

Might this be similar to an insurance assessor who decides what level of write-off a car is classified as following an accident?
Alternatively, if not that, maybe the (DVSA?) assessor who assesses that a Cat S car has been repaired to an adequate standard to return to the road? Although, as Kevin says, perhaps thats not the road we want to be led down given the Netherlands situation.

DVLA are happy to accept pre 2001 cars being converted and re-classifying them as ELECTRIC.

Does Boxster Ev's experience show that this is not now guaranteed to be the case? Or is it just covid-related inefficiency at completing the process?

[et0]

For what it's worth, I got my 2001 Insight re-registered as an EV no problem (W reg) - that was several years ago but I understood at the time that a newer car would have not been accepted.

The process was to send a few photos to DVLA to demonstrate that the vehicle really had been converted - I sent a work-in-progress battery box and view of the engine compartment with the motor fitted, number plate showing.

When I finally registered it on the road two years ago, I realised that although the V5C had the correct electric fuel type, the taxation class was still that of the original car! However that was sorted out with another email, and a few weeks wait. So, make sure you ask for that too.

For insurance purposes I use Adrian Flux and just told them it was self converted, I don't think they asked for any specifics.

In terms of what to do about more modern cars, we set up EVA Scotland a long time ago to deal with lobbying of this sort and it's worked quite well. I don't think this issue has been on the radar but I will raise it.
EVA England was also set up this year, there's no connection and I don't know the people involved, but I suspect it has the same sort of objective, would be worth someone contacting.

[bobby_come_lately]

So, I have had a fascinating response from my MP, who - fair play to him - passed my letter to the parliamentary undersecretary for transport who has responded at length.

Attaching the full letter here for you to read.

Key points:
"M1 and N1 type approved vehicles with a recorded CO2 emissions figure first registered on or after 1 March 2001 cannot move into an electric taxation class when the vehicle has been converted to an electric mode of propulsion."

I dispute that and would respond with a request that they specify exactly what part of the regulations state that since as far as I (and other legal parties) are concerned the regulations do not state that at all.

This is the crux of the matter as DVLA (and other involved persons it would appear) are not correctly interpreting the regulations which state that the CO2 figure of the vehicles in question (first regd. between 2001 and 2017) cannot be changed, but it does not state that the Taxation Class cannot be changed. This is a purely made up restriction. I queried DVLA on this specific point and they were unable to indicate where this was stated in the regs, so it wasn't just me missing it when reading them through again and again.

In fact, the main provisions of the regs DO state that "electrically propelled vehicles are exempt from VED" and correct interpretation of that means that the schedule regarding emission rates and levels (that cannot be changed) does not need to be considered. The statement above does NOT include any other restrictions regarding dates of first regn. etc. It is quite clear, but DVLA are entrenched in their view and cannot accept they are in fact wrong.

Fact is that prior to 2001, VED was based on capacity. Change to electric and that parameter becomes irrelevant even if still shown on the V5C after re-classification (I've no idea whether it is or not). DVLA are quite happy about this. But post 2001 (and before 2017) they get their knickers in a twist about the rate Schedule saying CO2 emissions figure cannot be changed. So what. It becomes irrelevant once it has been converted to electric, which as I said is clearly stated in the main provisions as being exempt and if they want, that CO2 figure can remain on the V5C, it is simply not relevant once the Taxation Class has been changed to ELECTRIC and unless anyone can actually show me where it states otherwise, there is NO part of the regs that prevent the TC being changed.

British law is always open to interpretation, but in this case the regs are actually quite clear and DVLA are just determined to obfuscate the issue with their own invented restrictions. I have no idea why they are so determined about this since they are clearly in the wrong and sadly I suspect government officials will often just defer to DVLA's judgement on such matters (no doubt lacking the ability to read and understand the regs themselves). I suspect it needs a court case with a correct ruling by a judge to force DVLA to accept that the law actually does NOT prevent 2001 - 2017 cars being converted to ELECTRIC Taxation Class and hence subject to the applicable rate of VED - currently exempt.

I do not believe this is a matter of the law as what it actually states is quite clear. It is a question of making those in charge understand and apply it correctly. In the current state of global demand for reduced pollution, it HAS to be seen as the right thing to do. Not just grudgingly accept that is what the law states, but even to actively encourage such conversions. The question remains, how are we to do this?

Would you be up for helping me write back to the minister on this point? Be great to make the argument on the law to her directly.

[bobby_come_lately]

EVA England was also set up this year, there's no connection and I don't know the people involved, but I suspect it has the same sort of objective, would be worth someone contacting.

Yep - already contacted (think I posted their response earlier in this thread).

[Boxster EV]

I've finally received another letter back from the DVLA. This saga has been going on since February 2020 and I've been phoning them every few weeks from August onwards in an effort to nudge them into action.

In summary, they've moved the goalposts. Despite providing everything requested in their previous letter (upon which they said the v5 changes could be made), they now wish to inspect the car. As the DVLA local offices no longer exist, they sub-contract the inspection out to a national firm called SGS engineering who will come to my home to complete the 20 minute inspection of the vehicle on the ground.

Having googled SGS, most of the information I've found regarding their inspections on the DVLA's behalf, relate to imported vehicles or cars that are being put back on the road without an audit trail (MOT history / V5 missing or old, or been off the road for some time). I've not managed to find anything related to EV conversions so it'll be interesting to see exactly what they're there to inspect. Google intimates they'll be checking the VIN number and that the car is indeed electric, and possibly that the car complies with the 'points system'.

The points system raises some concern because it could be open to interpretation what constitutes an unmodified monocoque (5pts), of which I'll need to reach a score of 8. My steering (2pts), suspension (2pts) and axles (2pts) are original.

The motor mounts on my build bolt into the car's original fixings so that wouldn't seem a concern. However, the boot floor has been adapted to incorporate the rear battery box...

Just to be clear, up until this point I have followed all of the anecdotal advice from this thread and elsewhere, and still ended up here. Therefore it seems that things are being tightened up.

Let's see where this goes. Obviously it's good that Zero EV have successfully gone through the DVLA rights of passage on a Boxster conversion, so I'll keep that precedent up my sleeve.

[johnfin]

[eUKenGB]

I've finally received another letter back from the DVLA. This saga has been going on since February 2020 and I've been phoning them every few weeks from August onwards in an effort to nudge them into action.

In summary, they've moved the goalposts. Despite providing everything requested in their previous letter (upon which they said the v5 changes could be made), they now wish to inspect the car. As the DVLA local offices no longer exist, they sub-contract the inspection out to a national firm called SGS engineering who will come to my home to complete the 20 minute inspection of the vehicle on the ground.

Having googled SGS, most of the information I've found regarding their inspections on the DVLA's behalf, relate to imported vehicles or cars that are being put back on the road without an audit trail (MOT history / V5 missing or old, or been off the road for some time). I've not managed to find anything related to EV conversions so it'll be interesting to see exactly what they're there to inspect. Google intimates they'll be checking the VIN number and that the car is indeed electric, and possibly that the car complies with the 'points system'.

The points system raises some concern because it could be open to interpretation what constitutes an unmodified monocoque (5pts), of which I'll need to reach a score of 8. My steering (2pts), suspension (2pts) and axles (2pts) are original.

The motor mounts on my build bolt into the car's original fixings so that wouldn't seem a concern. However, the boot floor has been adapted to incorporate the rear battery box...

Just to be clear, up until this point I have followed all of the anecdotal advice from this thread and elsewhere, and still ended up here. Therefore it seems that things are being tightened up.

Let's see where this goes. Obviously it's good that Zero EV have successfully gone through the DVLA rights of passage on a Boxster conversion, so I'll keep that precedent up my sleeve.

Remind me. What year is your Boxter?

[Boxster EV]

December 2000.

[eUKenGB]

December 2000.

That should make it as easy as it can be.

It's more than a bit worrying that an organisation whose raison d'être is purely bureaucratic actually wields so much power, yet is actually largely ignorant and obstructive at every opportunity.

As far as I'm concerned they'd all be on the first space ship to Golgafrincham along with the estate agents and marketing types.

[Speedy]

Unbelievable!!

[MX5EV]

Have you called any conversion shops in the UK and ask them what they needed to do to get conversions on the road?

https://zero-ev.co.uk/

[New Electric Ireland]

Have you called any conversion shops in the UK and ask them what they needed to do to get conversions on the road?

Historically it was a paper based system where the converter declared everything met the requirements and was safe. In reality the system was very widely abused and it's no surprise the authorities are now tightening up. Hopefully the UK will adopt a system like Ireland where an automotive engineer inspects the vehicle and writes a report... last thing they want is a system like The Netherlands which is really tough.

[SciroccoEV]

Have you called any conversion shops in the UK and ask them what they needed to do to get conversions on the road?

As I have said before, the problem with the DVLA is their lack of consistency. One one occasion the paperwork might go through without a glitch, on another every roadblock possible is dropped in your way. They once tried to fine me for not declaring SORN on a motorcycle that was off-road before SORN was introduced. Their system would not ALLOW me to declare SORN.

There is a way round the registration problem. Pay a specialist to do it for you. The DVLA will believe a complete pack of lies if it is done by a 'professional' company.

[MX5EV]

Well your not going to get anywhere unless you do something. Having dealt with bodies like UL/TUV/CSA on consumer equipment, you have only two options. Pre-Inspect it via a 3rd party then go to the inspection group or go directly to the inspection group. I can tell you the inspection always goes easier if you start by letting the inspector know it's already been gone through once, maybe providing a report, and they are less likely to be picky about what they find.

Can you keep registering using its original fuel source?

[New Electric Ireland]

Obviously it's good that Zero EV have successfully gone through the DVLA rights of passage on a Boxster conversion, so I'll keep that precedent up my sleeve.

The Zero EV solution is bolt in whereas you have cut the chassis. I suspect this is one of the reasons why DVLA want an automotive engineer to take a look.

[Boxster EV]

Obviously it's good that Zero EV have successfully gone through the DVLA rights of passage on a Boxster conversion, so I'll keep that precedent up my sleeve.

The Zero EV solution is bolt in whereas you have cut the chassis. I suspect this is one of the reasons why DVLA want an automotive engineer to take a look.

I think if you speak to Tom at Zero EV, he'll confirm that cutting modifications to the chassis rails were made on their car, and welding onto OEM crossmembers.

[New Electric Ireland]

I think if you speak to Tom at Zero EV, he'll confirm that cutting modifications to the chassis rails were made on their car, and welding onto OEM crossmembers.

I know Zero EV very well (I introduced the two founders) so I'm sure I can get some thoughts on how their conversion modifications differ from your removal of the boot floor.

For anyone reading this thread please review the DVLA point system before modifying the chassis. I suspect this will become a big focus on EV registration going forward.

Edit: while I wait for some feedback from Zero EV I think the message is clear that they avoid chassis modification (start at 5:20) "otherwise we end up modifying the chassis rails which is something we do not want to be doing"

[eUKenGB]

… The DVLA will believe a complete pack of lies if it is done by a 'professional' company.

Yup, that is my belief also.

[tom91]

I think if you speak to Tom at Zero EV, he'll confirm that cutting modifications to the chassis rails were made on their car, and welding onto OEM crossmembers.

The problem is that the DVLA class the fully welded/bonded assembly as the chassis, so this includes the boot floor. You would be surprised how much energy gets absorbed by a boot floor.

As for conversions by Zero-EV the rule of not modifying (drilling or cutting) any part of the vehicle that cannot be unbolted is a No Go.

The main issue is that there is no "Standard Process" for the DVLA to evaluate single builds/conversions. Since Paul's boxster is getting an inspection I am sure this will yield more information around where things are headed.