Super MoT threatens higher costs and restrictions

In mid-July, as reported at the time, the European Commission published proposals to mandate regular Road Worthiness Testing (RWT) for bikes, trikes and other road vehicles, in all EU member states.

You may remember, that more than 18 months ago, many of you completed a consultation on the subject, one which was incredibly badly drafted and which was only available in English. Great for the UK perhaps, but not so good for all the European countries who don’t use English as their first language. MAG member Jon Strong subsequently lodged a complaint with the European Ombudsman that it wasn’t fit for purpose, something the Ombudsman acknowledged was a case the Commission needs to answer.

I’m pleased to say that over 9000 people did respond to the consultation though, and it was noted that by far the highest proportion of respondents were riders, so thanks.

MAG is investigating the implications for Powered Two-Wheelers (PTW) – mopeds, motorcycles, sidecar outfits – and trikes, compared to the UK’s current ‘MoT’ test with the proposals for RWT.  We are in touch with the various UK authorities and are working in Europe with our FEMA colleagues.  The UK authorities are now holding a consultation (until Sept 5th) with invited parties, and don’t worry, MAG is involved. Formal discussions on these proposals at EU level will commence on 7th September.

The proposed RWT inspections go far beyond the current requirements for a bike MoT.  Riders and MoT stations would see some significant changes, and a £50.00 test fee seems likely based on the available data.

MAG(UK) believes the effect of the proposed additional tests and minimum requirements would be to transform the MoT we are familiar with into a Super-MoT – more extensive, more invasive, more costly.

Much of the evidence being offered to justify these changes appears to be flimsy and there is other evidence that indicates that any road safety or environmental benefits would be small compared to the costs of making the changes. From what we can see there appears to be little support for the proposals and we hope that by working with other organisations and politicians we will be successful in opposing the changes we are concerned about. In the meantime, we believe the proposals as they are currently drafted represent a real and genuine threat to biking as we know it.

MAG Netherlands and MAG Belgium are organising a protest ride to Brussels on the 22nd September  leaving at 11:00 from Hazeldonk south of Breda, along the A16 (E19) (just before the border crossing Netherlands-Belgium). It’s being supported by other FEMA rider organisations, such as those from Norway and even Germany, home of the TuV test.

Here in the UK, MAG is supporting the protest ride, but we’ll be doing something this side of the Channel too, if you can’t make it over to the Continent. We aren’t going to demonstrate at this stage as we are working with the Dept for Transport, but we are going to organise ‘ride-ins’ to MoT centres here to raise awareness of the new proposals and offer information and support. We are also planning the next stage of our own campaign on RWT which is where you, and good old letter writing begins again. It’s all to come in the next few weeks.

We have been warning of these developments for more than a year, well before the proposals were published.  During that time MAG has been campaigning to expose the EU’s failure to consult the public correctly before drafting the proposals.  After analysing the background material published by the Commission in July, MAG does not believe there is sufficient or  reliable evidence to support the proposals.  But in essence:

The goal of road worthiness testing is said to be “to check the functionality of safety components, the environmental performance and the compliance of a vehicle with its approval”

MAG’s main concerns about the proposals include:

  1. Modified vehicles: RWT is intended to check for modifications to the vehicle and ensure compliance with type-approval; DfT say this may prevent most modifications to vehicles without further approval of the vehicle and will apply to many components.  Even ‘Historic’ vehicles (over 30 years old) that were built before the Type-Approval system was introduced would be subject to checks – the Regulation allows them to be exempted from RWT, but only if they are of original appearance, including replacement components.  This would be both difficult to administer and counter-productive as many historic vehicles were supplied in non-standard form and modified for improved reliability, better lighting, etc. throughout their life.

  2. Cost and Complexity of the test: RWT tests would take longer, test more items, more rigorously and will require bike testing stations to invest in new equipment where measurement is not part of the current MoT
  • gas emission analysis / interrogation of On-Board Diagnostic equipment (this will require new testing equipment)
  • noise meter to decide borderline cases (this will require new testing equipment)
  • brake efficiency testing (DfT say this is may require changes to brake testing equipment)
  • brake fluid analysis (this will require new testing equipment)
  • efficiency of shock absorbers on trikes (this will require new testing equipment)
  • operation of security devices
  • more invasive testing (the Commission appears to want brake pads/shoes to be visually inspected for contamination of their surfaces)
  • all trailers capable of more than 25mph must be tested (DfT say this includes all trailers – eg; motorcycle trailers)
  • annual re-training of RWT inspectors (added cost)
  • creating an EU system linking national and manufacturers’ electronic vehicle databases so that records and road worthiness information about all vehicles will be available everywhere in the UK (subject to the Commission conducting a feasibility study)

3. Other impacts on riders

  • MAG believes there is a real possibility of a 40% increase in test fees to £50.00 for solo bikes (based on available comparative data provided by the Commission and national testing authorities)
  • Riders would also be faced with increased servicing and repair costs in order to meet the new test standard.
  • Fewer testing stations (the cost of new testing equipment may force small testers to give up, ALSO testers will have to avoid conflicts of interest, specifically ‘salary or any economic interest or personal benefit’ – this may mean larger, less local, dedicated testing centres if only testing OR repair is permitted)
  • RWT certificates must be kept on the vehicle (possibility of theft and damage to the certificate)
  • The Commission wants a re-test after any modifications to safety and environmental systems or components (this would be a decision for the UK authorities)
  • The Commission wants a re-test when the vehicle changes hands (this would be a decision for the UK authorities)
  • Dangerous faults would result in vehicle registration being ‘revoked’ until the vehicle passes another test (this suggests a re-registration fee of £25-55 based on DVLA’s current charges)

National governments may opt out of some aspects of RWT and also go beyond the minimum requirements in the Regulation, eg; the proposal for testing bikes and trikes after year-four and then every two years – UK government has already signalled it would not change the frequency of testing from the current year-three, then annual MoT frequency.

The date of implementation is expected to fall sometime between 2014-16 depending on progress of the Regulation.  There would be a transition period of up to five years after the new Regulations come in to force, during which time the existing MoT may continue.

This is a significant package of measures, with detailed annexes and three Impact Assessment documents. All documents relating to the proposals may be accessed at from the Commission web site.

Proposed Regulation:

Further detail about the test itself:

We will continue to inform you and ask of course, that you get involved. If you aren’t on our activist mailing list, please do sign up here