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Converting a van - Applications to DVLA for a Change of Body Type

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Legal requirement - when is a camper van not a motor caravan?

It has become apparent to us that there has been a change of policy at the DVLA regarding the approval of requests to change the Body type, as recorded on the V5C Registration Document, of previously registered commercial vehicles to 'Motor Caravan' after a conversion has been carried out, despite the published criteria here External link being met. This source states "the body type will not be changed unless the exterior of the vehicle actually appears to be a motor home" however no definition of what a 'motor home' should look like is provided. Also. below the list of 'minimum features, this statement appears: "If the vehicle has all of these features present, permanently fixed and installed properly, then it is a legal requirement to have it reclassified as a motor caravan on the V5C." Current DVLA policy seems to be preventing owners from meeting this legal requirement.

Previous flexibility 
We have had previous correspondence with DVLA on this subject, in particular from Gary Baker, who sent this response on 13 September 2011:
Thank you for your email of 28/07/11.  Apologies for the delay in replying we have been further reviewing our policy around the allocation of bodytype descriptions for motorcaravans taking into account the views of customers/key stakeholders like yourself.  Recognising the impact the policy may have on professional converters and our customers who self build I am pleased to inform you that following a further review the policy will allow greater flexibility for vehicles which have been modified both internally and externally from the manufacturers original specification after first registration and consideration will be given to conversions which have been carried out professionally where the customer can provide documentary evidence from the converter or a self build conversion where the customer can provide documentary evidence of the build.  

In addition to documentary evidence customers will still be required to provide external and internal photographic evidence of the conversion/build and also return their V5C for amendment.  As previously advised cases can vary significantly and DVLA deals with each case individually, based on the photographic and documentary evidence provided by the customer/registered keeper.  DVLA will continue to consider applications requesting a change of body type description but we will need to consider both the internal and external appearance of a vehicle. I should advise you that conversions will still be required to meet the internal criteria required for a motorhome/motorcaravan but greater flexibility will be applied to the external appearance of a vehicle. 
It now appears that the 'flexibility' mentioned by Mr Baker is no longer being applied, at least since around May 2019, as there are numerous reports, in online forums, of requests for a change of body type being refused and the V5C returned with the Body type recorded as 'Van with windows'. The reason being given is that the conversions do not 'look like' a motor caravan. Requests to DVLA for clarification on what criteria must be met in order for a conversion to 'look like' a motor caravan have not resulted in any definitive information being provided.
This is wholly unsatisfactory, both for professional conversion companies, and private individual converters. 
Having the Body type correctly recorded, to reflect the current published requirements, has implications beyond the actual 'use' of the vehicle. It can affect the ability of owners to insure their vehicles; to park their vehicles, for example in cases where commercial vehicles are excluded and indeed in locations where motor caravans are excluded; and may determine the speed limits that are applicable.
We asked for a definitive statement from DVLA that fully addresses this issue:
An email request resulted in this response:
"DVLA’s policy to take into consideration the external appearance of a “motor caravan” in describing a converted vehicle has been in place for many years and there have not been any recent changes. The guidance provided on the GOV.UK website confirms that “the body type will not be changed unless the exterior of the vehicle actually appears to be that of a motor home”.

DVLA receives many requests to change a vehicle’s body type to a “motor caravan” and these vehicles range in different shapes, sizes, and have various distinguishing features so we are unable to provide an exhaustive list of what we would expect to see on an application. However, following customer feedback, DVLA is currently working to further reword the guidelines and search links on GOV.UK. The aim is to provide further clarity for customers on information and actions to take regarding the conversion process."
Obviously quite unsatisfactory, so we submitted an FOI request. The DVLA responded to this by stating that they are considering whether releasing the information may 'prejudice the prevention or detection of crime'.
You can follow the course of our FOI request on the What Do They Know website here External link

On 21st October 2019 DVLA published revised guidelines covering the requirements for changing body type to motor caravan.

Essentially, to qualify for a change of body type the following requirements must be met:

External permanent features:

2 or more windows on at least one side of the main body (this does not include windows on the driver or passenger doors) to provide a reasonable amount of daylight into the living accommodation

A separate door which provides access to the living accommodation of the vehicle (this excludes the driver and passenger doors); a window on this door counts as a separate window on the main body

Motor caravan-style graphics on both sides of the vehicle

An awning bar attached to either side of the vehicle

A high-top roof (this does not include a pop-top elevating roof)

Internal features:

seats and a table

sleeping accommodation which may be converted from the seats

cooking facilities

storage facilities

The full guidance can be found here: https://www.gov.uk/government/publications/converting-a-vehicle-into-a-motor-caravanExternal link The page includes a downloadable checklist (Form V1006) which must accompany applications for a change of Body type to Motor Caravan.

The 'external permanent features' requirements do not seem to apply in the case of vehicles converted before first registration, if they have European Whole Vehicle Type Approval or National Small Series Approval.

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