When you make a motor vehicle, trailer, bodywork or component, you cannot simply start selling it. You must first obtain type-approval, prove your production conforms, and document it. This guide is for makers of motor vehicles, trailers and semi-trailers and their components and bodywork (SIC division 29) placing product on the market in Great Britain.
One distinction runs through this guide. Whole-vehicle and multi-stage type-approval, component and STU approval, and emissions and CO2 type-approval are a Great Britain matter — they apply when you place product on the market in England, Scotland or Wales, and the Vehicle Certification Agency (VCA) is the regulator. The duty to supply safe replacement and accessory parts, by contrast, applies across the UK, enforced by the Office for Product Safety and Standards (OPSS) and local Trading Standards — under the General Product Safety Regulations 2005 in Great Britain, and under the EU product-safety rules in Northern Ireland through the Windsor Framework. Check the Northern Ireland position separately if you sell there.
Whole-vehicle and multi-stage type-approval
Start here. Every complete vehicle, trailer, semi-trailer or caravan you place on the GB market needs whole-vehicle or multi-stage type-approval, backed by conformity of production and a certificate of conformity for each vehicle. If you complete a base vehicle as a bodybuilder or converter, you sit in the multi-stage build chain and must manage your stage of it.
Component and separate technical unit (STU) approval
If you make parts rather than complete vehicles — lighting, glazing, seats, mirrors, braking parts, couplings or electrical and mechanical sub-assemblies — those parts need component or STU type-approval and the prescribed approval markings before they go on the market. Approved parts are designed to satisfy the in-use construction standards.
Emissions and CO2 type-approval
Vehicles must also meet the applicable pollutant emission limits and the CO2 and fuel-economy requirements as part of type-approval, with the associated consumer information. Treat this as part of the same approval work, not a separate exercise.
Replacement and accessory part safety
The duty to supply safe replacement and accessory parts applies across the UK. In Great Britain the instrument is the General Product Safety Regulations 2005; in Northern Ireland the EU product-safety rules apply under the Windsor Framework, so check the Northern Ireland position separately. Where a part affects a regulated function — braking, steering, lighting, glazing, tyres or emissions control — it must also meet the relevant construction and, where required, component type-approval standards.
Steps to place your product on the GB market
Whichever of these regimes apply to what you make, the placing-on-market sequence is the same. Work through it in order; the early steps decide how much work the later ones involve.
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1. Classify your product
Identify exactly what you make — a complete vehicle or trailer, bodywork completed at a build stage, a component or STU, or a replacement or accessory part. This decides which approval route applies.
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2. Identify every applicable approval
List the approvals that bite. A complete vehicle engages whole-vehicle type-approval plus emissions and CO2; a part maker engages component or STU approval; a replacement-part maker engages product safety. Many makers engage more than one at once.
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3. Assess conformity against the applicable standards
Carry out the type-approval or conformity-assessment procedure for each applicable regime, testing against the relevant standards and emission limits. Higher-risk approvals are handled through the VCA.
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4. Set up conformity of production
Put in place the controls that show every unit you build matches the approved type, not just the test sample. Type-approval depends on ongoing conformity of production.
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5. Compile the technical documentation
Build and keep a technical file for each approval. You must be able to produce it for the VCA, OPSS or Trading Standards on request.
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6. Issue certificates of conformity and apply markings
Issue a certificate of conformity for each vehicle and apply the prescribed approval markings to approved components and STUs before they go on the market.
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7. Keep replacement parts safe and documented
For replacement and accessory parts, confirm each part is safe under the General Product Safety Regulations 2005, provide fitting information, and keep your records — this duty runs UK-wide.
What to do next
Placing product on the market is not the end of your duties. As a motor- vehicle maker you also carry ongoing UK-wide material duties — end-of-life vehicle producer responsibility and restricted substances under UK REACH. Read the companion guide on those ongoing duties, and run the sector compliance checklist before any production run or export. If you are unsure which approvals a particular product needs, confirm it with the VCA before you commit — it is far cheaper to check than to recall.
Official sources
Statutory sources and regulators for placing motor vehicles and parts on the GB market