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MoT: ARE WE EXEMPT? MoT -v- COMPLIANCE TEST CERTIFICATES:


Article by: David Lawrie, Director NPHTA dave@nphta.co.uk


www.nphta.co.uk


This month we focus on a long-running topic which affects the trade throughout the UK: the matter of local authorities that do not issue an actual Ministry of Transport certificate. Instead they rely on an exemption, as seen on the exemption form V112 here:-


https://assets.publishing.service.gov.uk/government/upl oads/system/uploads/attachment_data/file/925057/v112 -declaration-of-exemption-from-MoT.pdf.


…where it includes in the categories of vehicles that are exempt:


g) Hackney carriage or private hire vehicle licensed by local authorities authorised to check the road- worthiness of this vehicle


h) Hackney carriage licensed by Transport for London


Notice the wording here: “…local authorities authorised to check the road-worthiness” which means that in order for this exemption to apply at all, the local authority must hold the certificate of authorisation from the Ministry.


What is the difference?


Many local authorities will say that the compliance test is far stricter than a standard MoT. This is simply not the case at all; the roadworthiness element of the test is exactly the same: testing lights, tyres, suspension, bodywork, seat belts, ball joints, oil leaks and all other “roadworthiness” aspects which are a national standard as set by the Ministry of Transport.


The compliance test is ONLY testing that the vehicle “complies” with local authority vehicle conditions and policies, testing such things as: -


• The taximeter is set to the correct local tariff. • The roof light is working to the correct standards (some must be operated by the taximeter; others may have a separate switch to activate them).


• Testing to see that the fire extinguisher is present where required, and if required is marked with the vehicle registration number; also where required is certified as having been checked.


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• The same applies to first aid kits: are the contents within the “use-by” date etc.; remember, not all vehicles are required to have first aid kits or fire extinguishers, either of which are for driver or passenger use.


• Check that the vehicle is the correct colour to satisfy local conditions.


• Check the overall appearance of the vehicle inside and out - cosmetic, not mechanical.


As you can see, a compliance test is far from being a road- worthiness test, let alone being far more rigorous; nor can it be a national standard since there are so many variations amongst each local authority’s conditions, right down to age and colour of vehicle. Indeed, almost all of these checks can be performed whilst doing an actual MoT, since for example, the seats being dirty would be apparent whilst checking the seat belts. In fact in many cases, the compliance test does NOT include an emissions test.


“The two tests cannot be performed together!” Sez who?


On the face of it, it would make sense to have one test and one certificate as opposed to two separate tests - more convenient, right? Well actually, the two tests can be, and in fact in many regions are, performed at the same time by the nominated MoT testing centres, which is indeed then more convenient. This is the reason why the MoT test centres must be approved and authorised by the local authorities, since they are checking that the vehicle satisfies the relevant local authority conditions.


But is this a national exemption?


It actually is not, since firstly it is testing for local, not national conditions; and secondly, it only applies to those local authorities that are certified accordingly.


Furthermore, as we found out when attempting to create one of our regular tables, there are so many variations between local authorities, with answers such as:


• We issue both the compliance and the MoT certificate. • We only issue the compliance certificate and require an additional MoT to be supplied.


• What is the exemption to which you refer? • We only issue an MoT certificate and perform a visual vehicle check on application prior to issuing the plates. • We only issue the compliance certificate.


MAY 2021


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