Following concerted industry lobbying, the document thankfully lacks any reference to the infamous ‘4-2-2’ testing frequency proposal, which was finally abandoned late last year. 

The, much reduced, consultation document has proposals for a moderate increase in the test fee, expanded examination of number plates and introduces inspection of towbars (where fitted). 

The proposal to strengthen the current MoT check of registration-plates means that, in future, the following additional items would be checked so as to ensure: 

• The registration-plate background is not overprinted or shadowed with text;
• The front registration-plate has black characters on a white background;
• The rear registration-plate has black characters on a yellow background;
• The registration-plate does not obviously display a honeycomb (or similar effect) background
• The registration-plate does not have a non-reflective border obviously wider than permitted positioned too close to the characters.

In support of the proposal DfT claim that MOT Testing stations would not need new equipment in order to carry out the additional checks and, given that MOT testers already check registration-plates in MOT tests, it is not expected that the additional items of check would result in any additional test time. 

It is likely that additional vehicles will fail the MOT test during the first full year after the additional items have been introduced (whilst illegal registration-plates are being sifted out of the MOT-testable vehicle parc), but this will not result in any additional unfunded costs to MOT testing stations. 

Motorists who have illegal registration-plates that would be detected by the new check would have to purchase replacement (legal) plates. 

Forcing motorists with illegal registration-plates to replace them with compliant ones would aid road traffic enforcement, say the DfT, and therefore encourage compliance, deter road traffic offences, and help to improve road safety in a general sense. 

The question of what is illegal on registration plates has been the subject of lengthy correspondence between the ADF and DVLA. This follows news reports, in the autumn, claiming that motorists would soon be allowed to legally include the national flags of England, Scotland, wales and Northern Ireland on their registration plates.  After several letters over many months, the DVLA has confirmed that such registration plates are, technically, illegal.  However, both DfT and DVLA are unclear whether the new MoT rules mentioned above, will cause vehicles with national emblems on their plates to fail the test. 

Towbar checks 

The other main proposal in the consultation is a measure to ensure that any car or light goods vehicle which is presented for MOT test and which has a ‘towing hitch’ fitted would, in future, have the towing hitch itself, and the manner and integrity of the attachment of the towing hitch to the ‘parent vehicle’, checked as part of the MOT test of the vehicle. 

The proposed check would be fairly basic – that is, the check would be visual and similar in style and content to other aspects of the MOT test which are concerned with making an assessment of the structural integrity of load-bearing structures on the vehicle. As with all other aspects of the test – the check would be carried out without any element of dismantling by the tester – which means that only those parts of the towing hitch which could be seen would be subject to assessment. 

It is understood that the inspection would not require the tester to identify whether or not the towbar is ‘e’-marked, or to check the wear or ovality on the ball itself.