UK Statutory Instrument SI 2023/1394 United Kingdom

The Vehicle Emissions Trading Schemes Order 2023

Status
In Force
Penalty ceiling
Prosecution 3 of 84 obligations carry a fine up to £7,500. 6 carry different penalties and 75 have no criminal penalty — flagged in the list below.

Does it bind you?

Business-side roles with duties under this instrument.

Manufacturer40 Any Person15 Operator4 Applicant2

Plus 23 duties on the regulator, Crown ministers and public bodies — folded into the section list below.

Other Acts binding the same actors

If a role above is yours, these are the other instruments that most often bind it.

Manufacturer — also bound by 502 other Acts
Any Person — also bound by 2340 other Acts
Operator — also bound by 746 other Acts
Applicant — also bound by 307 other Acts

What it requires

Regulations creating concrete business duties or carrying penalties, grouped as the instrument is structured. Titles link to the source text — blue means you’re leaving for legislation.gov.uk.

Part 1

Introductory provisions

0 of 3 sections shown
3 other sections in this Part — procedural and definitional
s.art001 Citation and commencement
s.art002 Extent
s.art003 Interpretation
Part 2

Establishment and general provision in relation to the Trading Schemes

2 of 5 sections shown
s.art006 Administration of the Trading Schemes Regulated
Other duties (1) — Crown / regulator
  • Secretary of State must create and run the emissions trading registryCrown / Minister / Government department
s.art008 Pool participants in the Trading Schemes: general Prosecution
  • Fail to meet pooled emissions scheme obligationsManufacturer

Unlimited fine

3 other sections in this Part — procedural and definitional
s.art004 Establishment of the Trading Schemes
s.art005 Period by reference to which the Trading Schemes operate
s.art007 Allowances and credits: general
Part 3

The Trading Schemes

40 of 72 sections shown
s.art013 Allocation of CRTS allowances Regulated
Other duties (1) — Crown / regulator
  • Administrator must allocate CRTS allowances according to formulaCrown / Minister / Government department
s.art015 Borrowing CRTS allowances Regulated
  • Borrow CRTS allowances within set limits and repay with surchargeManufacturer
s.art016 Banked allowances: pool CRTS participants Regulated
Other duties (1) — Crown / regulator
  • Administrator must transfer banked pool allowances to departing membersCrown / Minister / Government department
s.art017 Borrowed allowances: pool CRTS participants Regulated
  • Account for borrowed allowances when leaving a poolManufacturer
s.art020 CRTS credits: car clubs (CRTS participants) Regulated
  • Ensure car club vehicles meet 18-month exclusive use condition for CRTS creditsManufacturer
s.art022 CRTS credits: car clubs (SPV car manufacturers) Regulated
  • Forfeit a CRTS credit if a ZE SPV you claimed for is not used by a car club as requiredManufacturer
s.art023 CRTS credits: conversion of unused VRTS allowances by a CRTS participant which is also a VRTS participant Regulated
  • Convert unused VRTS allowances into CRTS credits at 2:1 ratioManufacturer
s.art023 CRTS credits: conversion of VRTS credits by a CRTS participant which is also an SPV van manufacturer Regulated
  • Do not trade CRTS credits acquired through VRTS credit conversionManufacturer
s.art025 Trading CRTS allowances and credits: CRTS participants Regulated
  • Trade CRTS allowances and credits within rules and notify the administratorManufacturer
s.art026 Trading CRTS credits with CRTS participants: SPV car manufacturers Regulated
  • Trade CRTS credits only within allowed trading window and notify the administratorManufacturer
s.art026 Trading CRTS credits with VRTS participants: SPV car manufacturers Regulated
  • Notify the administrator of CRTS credit trades with VRTS participantsManufacturer
s.art027 Accounting for activity in the CRTS Regulated
  • Surrender CRTS allowances or credits for your scheme activity within deadlineManufacturer
s.art028 Payments: CRTS Regulated
  • Pay for shortfall in CRTS allowances or creditsAny Person
s.art029 Banked or borrowed CRTS allowances of former CRTS participants Regulated
  • Settle borrowed CRTS allowances after leaving the schemeAny Person
s.art030 Expiry of CRTS allowances and CRTS credits Regulated
Other duties (1) — Crown / regulator
  • Administrator must record expiry of CRTS allowances and credits in the registryStatutory regulator
s.art034 Allocation of CCTS allowances Regulated
Other duties (1) — Crown / regulator
  • Administrator must allocate CCTS allowances using the N × B formulaStatutory regulator
s.art036 Measuring activity in the CCTS Regulated
  • Account for units of activity in the CCTS based on NZE car emissionsManufacturer
s.art037 Trading CCTS allowances Regulated
  • Notify administrator of CCTS allowance trades before end of trading windowManufacturer
s.art038 Accounting for activity in the CCTS Regulated
  • Surrender CCTS allowances for your activity each yearAny Person
s.art039 Payments: CCTS Regulated
  • Pay for insufficient CCTS allowancesManufacturer
s.art040 Expiry of CCTS allowances Regulated
Other duties (1) — Crown / regulator
  • Administrator must record expiry of CCTS allowances in the registryStatutory regulator
s.art045 Allocation of VRTS allowances Regulated
Other duties (1) — Crown / regulator
  • Administrator must allocate VRTS allowances to van manufacturersStatutory regulator
s.art047 Borrowing VRTS allowances Regulated
  • Borrow and repay VRTS allowances within limits and deadlinesManufacturer
s.art048 Banked allowances: pool VRTS participants Regulated
Other duties (1) — Crown / regulator
  • Administrator must transfer banked pool allowances to departing members and update registryStatutory regulator
s.art049 Borrowed allowances: pool VRTS participants Regulated
  • Account for borrowed allowances when leaving a pool VRTS participantManufacturer
s.art052 VRTS credits: car clubs (VRTS participants) Regulated
  • Account for VRTS credits if car club vehicle fails exclusive use conditionManufacturer
s.art054 VRTS credits: car clubs (SPV van manufacturers) Regulated
  • Forfeit VRTS credits if car-club vans are not used for 18 monthsManufacturer
s.art055 VRTS credits: conversion of CRTS credits by a VRTS participant which is also an SPV car manufacturer Regulated
  • Request conversion of CRTS credits to VRTS credits during the trading windowManufacturer
s.art057 Trading VRTS allowances and credits: VRTS participants Regulated
  • Notify administrator of VRTS trades and comply with trading restrictionsManufacturer
s.art058 Trading VRTS credits with VRTS participants: SPV van manufacturers Regulated
  • Comply with trading rules and notify the administrator when trading VRTS creditsManufacturer
s.art059 Accounting for activity in the VRTS Regulated
  • Surrender VRTS allowances or credits for your scheme year activity by 31st DecemberManufacturer
s.art060 Payments: VRTS Regulated
  • Make payment for shortfall in VRTS allowances or creditsAny Person
s.art061 Banked or borrowed VRTS allowances of former VRTS participants Regulated
  • Account for borrowed VRTS allowances after leaving the schemeAny Person
s.art062 Expiry of VRTS allowances and VRTS credits Regulated
Other duties (1) — Crown / regulator
  • Administrator must record expiry of VRTS allowances and creditsStatutory regulator
s.art066 Allocation of VCTS allowances Regulated
Other duties (1) — Crown / regulator
  • Administrator must allocate VCTS allowances to participants each yearStatutory regulator
s.art068 Measuring activity in the VCTS Regulated
  • Account for CO₂ emissions of NZE vans in the VCTS each scheme yearManufacturer
s.art069 Trading VCTS allowances Regulated
  • Trade VCTS allowances correctly and notify the administratorAny Person
s.art070 Accounting for activity in the VCTS Regulated
  • Surrender VCTS allowances for scheme year activity by 31st DecemberAny Person
s.art071 Payments: VCTS Regulated
  • Pay £86 per unit for shortfall in VCTS allowancesAny Person
s.art072 Expiry of VCTS allowances Regulated
Other duties (1) — Crown / regulator
  • Administrator must record expired VCTS allowances in the registryStatutory regulator
32 other sections in this Part — procedural and definitional
s.art009 Interpretation of Chapter 1
s.art010 Activity to which the CRTS applies and unit of measurement of activity
s.art011 Participants in the CRTS
s.art012 CRTS allowances and limits on CRTS allowances and CRTS activity
s.art014 Banking CRTS allowances
s.art018 CRTS credits: general
s.art019 CRTS credits: registration of ZE SPVs (CRTS participants)
s.art021 CRTS credits: registration of ZE SPVs (SPV car manufacturers)
s.art023 CRTS credits: conversion of unused CCTS allowances
s.art024 Measuring activity in the CRTS
s.art025 Trading CRTS allowances with VRTS participants
s.art031 Activity to which the CCTS applies and unit of measurement of activity
s.art032 Participants in the CCTS
s.art033 CCTS allowances
s.art035 Conversion of unused CRTS allowances into CCTS allowances
s.art041 Interpretation of Chapter 3
s.art042 Activity to which the VRTS applies and unit of measurement of activity
s.art043 Participants in the VRTS
s.art044 VRTS allowances and limits on VRTS allowances and VRTS activity
s.art046 Banking VRTS allowances
s.art050 VRTS credits: general
s.art051 VRTS credits: registration of ZE SPVs (VRTS participants)
s.art053 VRTS credits: registration of ZE SPVs (SPV van manufacturers)
s.art055 VRTS credits: conversion of unused VCTS allowances
s.art055 VRTS credits: conversion of unused CRTS allowances by a VRTS participant which is also a CRTS participant
s.art056 Measuring activity in the VRTS
s.art057 Trading VRTS allowances with CRTS participants
s.art058 Trading VRTS credits with CRTS participants: SPV van manufacturers
s.art063 Activity to which the VCTS applies and unit of measurement of activity
s.art064 Participants in the VCTS
s.art065 VCTS allowances
s.art067 Conversion of unused VRTS allowances into VCTS allowances
Part 4

Information

11 of 12 sections shown
s.art073 Information: participants in the Trading Schemes Regulated
  • Provide vehicle emissions data to the administratorManufacturer
s.art074 Information: SPV manufacturers Regulated
  • Notify administrator and provide vehicle data to obtain emissions creditsManufacturer
s.art075 Maintenance and audit of records by participants in the Trading Schemes Regulated
  • Keep records and audit them annually for vehicle emissions tradingManufacturer
s.art076 Maintenance and audit of records by SPV manufacturers Regulated
  • Keep records and annually audit ZE SPV data for CRTS/VRTS creditsManufacturer
s.art077 Preparation of provisional information Regulated
Other duties (1) — Crown / regulator
  • Administrator must prepare and notify provisional emissions data annuallyCrown / Minister / Government department
s.art078 Error notification Regulated
  • Notify the administrator of errors in provisional emissions informationManufacturer
s.art079 Preparation and notification of final information Regulated
Other duties (1) — Crown / regulator
  • Administrator must prepare and notify final emissions information by 31st OctoberStatutory regulator
s.art081 Power of administrator to require information from participants and SPV manufacturers Regulated
  • Provide information to the administrator when requestedManufacturer
s.art082 Updating information provided with an application under Part 3 of Schedule 4 (low-volume participants) Regulated
  • Notify administrator of changes affecting low-volume participant statusAny Person
s.art083 Updating information provided with an application under Schedule 5 (pool participants) Regulated
  • Notify administrator of change to pool contact point manufacturerManufacturer
s.art084 Manner of provision of information to administrator Regulated
  • Submit information and notifications to the administrator via their websiteManufacturer
1 other section in this Part — procedural and definitional
s.art080 Publication of final information
Part 5

Monitoring compliance and enforcement

1 of 8 sections shown
s.art092 Enforcement notices Regulated
  • Comply with enforcement notices from the emissions trading administratorManufacturer
7 other sections in this Part — procedural and definitional
s.art085 Powers of administrator in respect of monitoring compliance
s.art086 Power to require production of documents or provision of information
s.art087 Power to question officers of a company
s.art088 Powers of entry, etc
s.art089 Seizure of documents or records
s.art090 Warrant
s.art091 Legal professional privilege
Part 6

Civil penalties

8 of 14 sections shown
s.art095 Non-financial penalties: general Regulated
  • Receive a block or publication for non-compliance with the Vehicle Emissions Trading SchemeAny Person
s.art097 Failure to make a payment to account for activity in the Trading Schemes Regulated
  • Fail to pay amounts due under emissions trading schemeAny Person
s.art098 Failure to provide information under article 73 Regulated
  • Fail to provide required information to the emissions trading administratorAny Person
s.art099 Failure to maintain records Prosecution
  • Fail to maintain records under Vehicle Emissions Trading SchemesManufacturer

Fine up to £7,500

s.art100 Failure to provide information under article 81 (information required for the purposes of administering the Trading Schemes) Prosecution
  • Fail to provide information requested under vehicle emissions trading schemeManufacturer

Fine up to £7,500

s.art101 Failure to provide information under article 86 (information required where suspected failure to comply with this Order) Prosecution
  • Fail to provide information on suspected non-complianceManufacturer

Fine up to £750,000

s.art102 Failure to make officer available for questioning Prosecution
  • Fail to make officer available for questioningManufacturer

Fine up to £75,000

s.art104 Failure to comply with enforcement notice Prosecution
  • Fail to comply with an enforcement noticeManufacturer

Fine up to £7,500

6 other sections in this Part — procedural and definitional
s.art093 Civil penalties: general
s.art094 Financial penalties: general
s.art096 Waiver and modification of civil penalties
s.art103 Refusal to allow access to premises
s.art105 Provision of false or misleading information: participants in the Trading Schemes
s.art106 Provision of false or misleading information: SPV manufacturers
Part 7

Appeals

1 of 2 sections shown
s.art108 Appeal against decisions of the administrator Regulated
  • Appeal administrator decisions to the First-tier TribunalManufacturer
1 other section in this Part — procedural and definitional
s.art107 Decisions to which this Part applies
Part 8

Revocation, amendment and saving of EU Regulations relating to CO2 emission limits

0 of 8 sections shown
8 other sections in this Part — procedural and definitional
s.art109 Interpretation of Part 8
s.art110 Partial revocation and amendment of Regulation (EU) 2019/631
s.art111 Amendment of Regulation (EU) 725/2011 (eco-innovation for passenger cars)
s.art112 Amendment of Regulation (EU) 427/2014 (eco-innovations for light commercial vehicles)
s.art113 Partial revocation and amendment of Regulation (EU) 1014/2010 and Regulation (EU) 293/2012 (monitoring and reporting of data on vehicle registration)
s.art114 Partial revocation and amendment of Regulation (EU) 63/2011 and Regulation (EU) 114/2013 (derogations)
s.art115 Revocation of Regulation (EU) 2017/1152 and Regulation (EU) 2017/1153
s.art116 Savings for monitoring and compliance in relation to Great Britain
Part 9

Miscellaneous

1 of 2 sections shown
s.art118 Review Regulated
Other duties (1) — Crown / regulator
  • Secretary of State must review the Order and publish a reportCrown / Minister / Government department
1 other section in this Part — procedural and definitional
s.art117 Crown application
Schedules

Schedules

20 of 124 shown
s.sch002 The operator ensures that the vehicles used for the purpose... Regulated
  • Keep car club vehicles roadworthy, insured, and covered by breakdown recoveryOperator
s.sch002 The operator has and publishes— (a) an equality and diversity... Regulated
  • Publish equality, environmental and complaints policies for your car clubOperator
s.sch002 If the operator intends to cease providing the car club... Regulated
  • Give customers two months' notice before ceasing car club serviceOperator
s.sch002 The operator provides the following information to the administrator within... Regulated
  • Provide annual and ongoing information to the administrator about zero-emission car club vehiclesOperator
s.sch003 The administrator must keep under review whether the multiplier of... Regulated
Other duties (1) — Crown / regulator
  • Administrator must review multiplier for CO2 calculation of completed vansStatutory regulator
s.sch003 The administrator must keep under review the representativeness of monitoring... Regulated
Other duties (1) — Crown / regulator
  • Administrator must review CO2 monitoring accuracy for completed vansCrown / Minister / Government department
s.sch003a The administrator must, within the decision period— Regulated
Other duties (1) — Crown / regulator
  • Administrator must grant or reject applications within the decision periodStatutory regulator
s.sch003a The notification required by paragraph 10 must be in writing... Regulated
Other duties (1) — Crown / regulator
  • Administrator must send written decision notice with required detailsStatutory regulator
s.sch003a Where the administrator grants an application under this Schedule in... Regulated
Other duties (1) — Crown / regulator
  • Administrator must determine CO2 emissions when approving vehicle applicationsStatutory regulator
s.sch004 An application under this Part must be accompanied by the... Regulated
  • Include all required business and vehicle data in your CRTS/VRTS applicationApplicant
s.sch004 For a vehicle which has an individual vehicle approval certificate,... Regulated
  • Use vehicle approval certificate to satisfy information requirementsApplicant
s.sch004 A revocation under paragraph 17 must be notified by the... Regulated
Other duties (1) — Crown / regulator
  • Administrator must notify participant of revocation in writingStatutory regulator
s.sch005 An application under this Schedule must be made on or... Regulated
  • Submit pool participation application by 30th AprilManufacturer
s.sch005 For the purposes of paragraph 5(b)— (a) if an application... Regulated
  • Apply for paired trading schemes when making an applicationAny Person
s.sch005 An application under this Schedule must be accompanied by evidence... Regulated
  • Submit evidence of manufacturer connection and capability with applicationManufacturer
s.sch007 For a van which is fuelled by both petrol and... Regulated
Other duties (1) — Crown / regulator
  • Administrator must record CO2 emissions for petrol-ethanol (E85) vansStatutory regulator
s.sch007 The information mentioned in sub-paragraphs (t), (u) and (v) of... Regulated
  • Provide specified information to the administrator when requested in writingAny Person
s.sch007 For a car to which this paragraph applies, the administrator... Regulated
Other duties (1) — Crown / regulator
  • Administrator must record CO2 emissions for LPG/CNG carsStatutory regulator
s.sch007 The information mentioned in sub-paragraphs (u), (v) and (w) of... Regulated
  • Provide requested information to the emissions trading scheme administratorAny Person
s.sch007 For a van to which this paragraph applies, the administrator... Regulated
Other duties (1) — Crown / regulator
  • Administrator must record CO2 emissions for LPG/CNG vansStatutory regulator
104 other schedules
s.sch001 Interpretation and general
s.sch001 Existing manufacturer in non-compliant pool met individual 2021 target
s.sch001 Where this paragraph applies, the CCTS participant’s baseline is the...
s.sch001 Existing manufacturer in non-compliant pool did not meet individual 2021 target
s.sch001 Where this paragraph applies, the CCTS participant’s baseline is the...
s.sch001 New manufacturer in 2022
s.sch001 Where this paragraph applies, the CCTS participant’s baseline is the...
s.sch001 New manufacturer in 2023
s.sch001 Where this paragraph applies, the CCTS participant’s baseline is the...
s.sch001 New manufacturer from 2024
s.sch001 Where this paragraph applies, the CCTS participant’s baseline is the...
s.sch001 Paragraphs 5 to 19 apply for the purposes of calculating...
s.sch001 Pool CCTS participant
s.sch001 Interpretation and general
s.sch001 Paragraphs 25 to 39 apply for the purposes of calculating...
s.sch001 Paragraph 40 applies for the purposes of calculating the baseline...
s.sch001 A baseline which is calculated in accordance with this Part,...
s.sch001 Existing manufacturer which met 2021 target
s.sch001 Where this paragraph applies, the VCTS participant’s baseline is the...
s.sch001 Exempt manufacturer for 2021
s.sch001 Existing manufacturer which did not meet 2021 target
s.sch001 Where this paragraph applies, the VCTS participant’s baseline is the...
s.sch001 Paragraph 20 applies for the purposes of calculating the baseline...
s.sch001 Existing manufacturer in non-compliant pool met individual 2021 target
s.sch001 Where this paragraph applies, the VCTS participant’s baseline is the...
s.sch001 Existing manufacturer in non-compliant pool did not meet individual 2021 target
s.sch001 Where this paragraph applies, the VCTS participant’s baseline is the...
s.sch001 New manufacturer in 2022
s.sch001 Where this paragraph applies, the VCTS participant’s baseline is the...
s.sch001 New manufacturer in 2023
s.sch001 Where this paragraph applies, the VCTS participant’s baseline is the...
s.sch001 New manufacturer from 2024
s.sch001 Where this paragraph applies, the VCTS participant’s baseline is the...
s.sch001 A baseline which is calculated in accordance with this Part,...
s.sch001 Pool VCTS participant
s.sch001 Existing manufacturer which met 2021 target
s.sch001 Where this paragraph applies, the CCTS participant’s baseline is the...
s.sch001 Exempt manufacturer for 2021
s.sch001 Existing manufacturer which did not meet 2021 target
s.sch001 Where this paragraph applies, the CCTS participant’s baseline is the...
s.sch002 The conditions which must be met by a person (referred...
s.sch002 The operator offers a service to the public (a “car...
s.sch003 General
s.sch003 Monitoring emissions of CO2: modifications relating to fuel consumption and CO2 emissions
s.sch003 The formula in this paragraph is: DMbase = (MRObase x...
s.sch003 The mass representative of the vehicle load for the purposes...
s.sch003 Where DMbase is lower than TML, TMind is replaced by...
s.sch003 Where DMbase is higher than TMH, TMind is replaced by...
s.sch003 For a completed van which is subject to individual vehicle...
s.sch003 Monitoring emissions of CO2: modifications relating to aerodynamic drag
s.sch003 Where this paragraph applies, the manufacturer of the base vehicle...
s.sch003 Paragraph 19 applies where— (a) the interpolation method is not...
s.sch003 Where this paragraph applies, Af is replaced by the frontal...
s.sch003 If, following the review in paragraph 2, the administrator finds...
s.sch003 If, following the review in paragraph 4, the administrator finds...
s.sch003 Specific emissions of CO 2 of a completed van which undergoes emissions testing at the final stage
s.sch003 Specific emissions of CO 2 of a completed van based on a complete base vehicle
s.sch003 Specific emissions of CO 2 of a completed van based on an incomplete base vehicle: general
s.sch003 The monitoring emissions of CO2 of an incomplete base vehicle...
s.sch003a In this Schedule— “ charge-depleting Type 1 test ” means...
s.sch003a If an application under this Schedule, other than a further...
s.sch003a If an application under this Schedule is rejected as invalid, the...
s.sch003a In this Part, “ decision period ”, in relation to...
s.sch003a If the application met Condition A or Condition B, the...
s.sch003a If the application met Condition C, but not Condition B,...
s.sch003a For the purposes of calculating the values referred to in...
s.sch003a A CCTS participant may apply for the specific emissions of...
s.sch003a A VCTS participant may apply for the specific emissions of...
s.sch003a An application under this Schedule is valid if it—
s.sch003a Condition A is that the application— (a) is accompanied by—...
s.sch003a Condition B is that the application— (a) is accompanied by—...
s.sch003a Condition C is that the application— (a) is accompanied by—...
s.sch003a The information specified in this paragraph is—
s.sch003a The information specified in this paragraph is—
s.sch004 A CRTS participant may be treated as a low-volume CRTS...
s.sch004 For a vehicle in relation to which an administrator has...
s.sch004 The administrator may only reject an application made under this...
s.sch004 If a valid application is made under this Part and...
s.sch004 Where an application is granted in accordance with paragraph 13,...
s.sch004 Where an application is rejected in accordance with paragraph 12(b),...
s.sch004 An applicant which ceases to be a low-volume CRTS participant...
s.sch004 An application granted under this Part may be revoked by...
s.sch004 For the purposes of paragraph 1(c)— (a) a participant operates...
s.sch004 A CRTS participant which is the manufacturer of fewer than...
s.sch004 A VRTS participant which is the manufacturer of fewer than...
s.sch004 A CRTS participant which is the manufacturer of fewer than...
s.sch004 A VRTS participant which is the manufacturer of fewer than...
s.sch004 An application under this Part may not relate to the...
s.sch004 A CRTS participant or VRTS participant which makes an application...
s.sch004 An application under this Part must be—
s.sch005 Two or more manufacturers may together apply to the administrator...
s.sch005 An application under this Schedule may relate to a single...
s.sch005 An application under this Schedule may only be made by...
s.sch005 An application under this Schedule must identify—
s.sch005 The administrator may only reject an application under this Schedule...
s.sch005 Where the administrator grants an application made in accordance with...
s.sch007 The information referred to in article 73(1)(a) and article 74(3)(a)...
s.sch007 The information referred to in article 73(1)(c) is set out...
s.sch007 Where the completed van is based on an incomplete base...
s.sch007 Where the completed van is based on a complete base...
s.sch007 Paragraph 4 applies in relation to a car which is...
s.sch007 For a car which is fuelled by both petrol and...
s.sch007 The information referred to in article 73(1)(b) and article 74(3)(b)...
s.sch007 Paragraph 9 applies in relation to a van which is...

Duty extraction and severity labels are Guvnor’s analysis of the instrument, not the instrument itself. Always verify against the linked source text.