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Dear Jean-Paul,

EC Harmonised IVA and US imports to the UK

Further to my letter of 1 September on the subject of EC IVA, I would like to raise afurther concern which is very important to stakeholders in the UK and seek yourassistance.

In the UK there has been for many years an industry centred around importation ofAmerican cars, both classic and new. This consists of many small businesses concernedwith importation of such vehicles, and the supply of servicing and spare parts.

We in DfT have worked closely with the trade body which represents this industry, theAmerican Import Agents Association (AIAA). After much work, our previous SVA (SingleVehicle Approval) scheme was modified to enable new American vehicles to continue tobe imported. We have worked together again on our new IVA scheme to ensure thatthese vehicles undergo a suitable and proportionate inspection, which recognises thatthey comply with the high environmental and safety standards applicable in the USAwhilst requiring certain key modifications for the UK market.

The clarification received at the last meeting in September that Harmonised IVA is likelyto apply to these vehicles (since they are mass-produced) is of grave concern to the smallbusinesses that import American vehicles. Despite the welcome recognition of manyFMVSS standards by the scheme, certain elements of the Harmonised IVA scheme are

likely to make import of these vehicles uneconomic and will cause enormous difficulties tothe UK businesses concerned.

We fully accept that in other Member states, where vehicles are driven on the same sideof the road as in the USA, there is a need to prevent uncontrolled importation of newvehicles without type approval (circumvention of type approval) but the situation in the UKis different due to the fact we drive on the left. This naturally restricts the market for newAmerican vehicles (designed for driving on the right) to enthusiasts. Since the introductionof the SVA scheme in 1998, the volumes of these vehicles imported into UK haveremained very low.

We are very keen to assist the small companies in this field to continue in business, andthus would like to request your assistance in finding a way to maintain the current UK IVA

Jean-Paul DelneufcourtAutomotive Industry Unit - F1

Directorate General Enterprise andIndustryEuropean Commission

Mike LoweSenior Policy AdvisorTransport Technology and StandardsDepartment for TransportZone 2/01 Great Minster House76 Marsham StreetLONDON. SW1P 4DRDirect Line: 020 7944 2073Fax: 020 7944 2196

email: mike.lowe@dft.gsi.gov.uk

Web Site: www.dft.gov.uk

24 November 2009

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scheme for left-hand-drive American vehicles, as an exemption to the general rule thatmass-produced vehicles must undergo Harmonised IVA. We would be content - ifabsolutely necessary - to consider a limitation on volumes for these vehicles.

I would be happy to elaborate on the comments above over the phone or at a meeting, ifyou wish.

An early response would be very much appreciated.

Yours sincerely,

Mike

Mike Lowe