The revision of UK and International Road Haulage Rules (mobility package) in August 2020 brought in a series of changes over a given timeline, including changes to drivers’ hours rules, tachographs, and operator licensing.
One of the changes includes the requirement for operator licensing to be applied to vehicles heavier than 2.5 tonnes and up to 3.5 tonnes used for hire or reward engaged in international transport. This covers the transport of goods in the EU, Iceland, Liechtenstein, Norway, and Switzerland. This new requirement comes into force from 21 May 2022. Previously operator licensing only applied to vehicles or combinations exceeding 3.5 tonnes gross plated weight.
HOW DOES THIS AFFECT OPERATORS WHO WILL FALL INTO SCOPE FROM 21 MAY 2022?
If you already have a standard international goods vehicle operator licence you will need to add vehicles over 2.5 tonnes and up to 3.5 tonnes onto your existing operator licence.
Light Commercial Vehicles (LCVs) and cars towing trailers where the Gross Train Weight (GTW) is over 2.5 tonnes used for hire or reward on international journeys will need to be added to your operator licence. Where there is insufficient capacity, and an increase in the vehicle limit is required, a major variation will need to be applied for at a cost of £257.
VAN ONLY FLEETS
Operators that purely operate vans (Light Commercial Vehicles) on international journeys for hire or reward that have never held a goods vehicle operator licence, will need to apply for a Standard International Operator Licence. Operators in this category will need to meet the requirements for an operator licence which will include appointing a transport manager and having the required financial standing. This specific information will need to be evidenced at time of application.
When comparing the criteria that must be met with those needed to apply for an operator licence to operate larger goods vehicles there are some noticeable differences. These include transport manager qualifications (temporary exemption), financial standing and operating centres.
TRANSPORT MANAGER
There is a requirement to appoint a designated transport manager as part of the requirement to obtain a Standard International Operator Licence. The options available for light commercial vehicles also include a temporary exemption from the requirement to hold a TM CPC qualification.
A company can employ a suitably qualified transport manager, hire an external transport manager, or apply for an existing member of staff to become temporarily recognised as a transport manager as long as they have at least 10 years’ experience managing fleets of vehicles before August 2020. They will then have until 21 May 2025 to pass the Transport Manager CPC (Certificate of Professional Competence) qualification if they wish to continue as a transport manager after this date.
FINANCIAL STANDING
Where Light Commercial Vehicles and cars and trailers are concerned, an operator will need sufficient financial standing for the vehicles in their fleet. The requirement is £1600 for the first vehicle and £800 per additional light commercial vehicle or car and trailer. This is a lower fee in comparison to the requirement for operators of HGVs on a Standard International Licence, which require £8000 for the first vehicle and £4500 per subsequent vehicle.
OPERATING CENTRE
When applying for an operating centre for HGVs, approval is required for the operating centre, which also includes an advert in the local paper. Where a company is applying for an operator licence purely for light commercial vehicles, there is no requirement to apply for approval for a specific operating centre or advertise the operating centre in the local newspaper.
MAINTENANCE
Guidance and criteria for maintenance requirements can be found in the Guide to maintaining roadworthiness.
Light commercial vehicles which will now fall in scope of operator licensing will also come under the requirement to have safety inspections carried out at a regular frequency which will need to be specified on the operator licence. As most light commercial vehicles are governed by manufacturers’ guidelines for servicing etc, this may require an amendment to the current maintenance contract to incorporate the required safety inspections at the predetermined intervals as stated on your operator licence.
INTERIM LICENCE
If you need a licence quickly, at the time of application you will need to request an interim licence which is also referred to as a time limited interim authority. This will allow you to start operating while the full licence is being processed.
The cost of applying for a licence will be the usual application fee of £257 plus an additional £68 for the interim application.
Hopefully the application for a full licence will be successful. The £401 fee for the full operator licence will then be required. A renewal or continuation fee of £401 will need to be paid every five years.
UK LICENCE FOR THE COMMUNITY
A UK Licence for the Community is also required (formerly the EU Community Licence), which should be requested when applying for the interim licence. A Licence for the Community includes an office copy – which must be kept at the main office and certified copies for each of the vehicles authorised on the standard international operator licence.
There is a requirement to carry a certified copy in the vehicle when transporting goods in or through EU countries. The certified copies are not specific to any one vehicle.
A UK Licence for the Community is a requirement if you make journeys for hire or reward within the EU, Liechtenstein, Norway, and Switzerland.
CONCLUSION
If you fall in scope of the requirements from 21 May 2022 and do not hold a Standard International Goods vehicle operator licence you will no longer be able to transport goods for hire or reward in the EU, Liechtenstein, Norway, and Switzerland.
Where you only operate light commercial vehicles domestically (only use your vehicles in the UK) or are not transporting goods for hire or reward internationally, you will not fall in scope of operator licensing.
www.logistics.org.uk/mac
