Assembly of flat pack trailers

We have had several enquiries relating to the assembly of flat pack trailers once the new Type Approval regulations come into force at the end of October. As there seems to be considerable confusion surrounding this topic it may be helpful if we publish the official line from the Department for Transport as kindly provided to us by the VCA.

References:

Directive: 2007/46, Article 2, paragraph 1, and Annex X, paragraph 0.1

2002/24 Article 1, paragraph 1 and Annex VI, paragraph 1.1.2

2003/37 Article 1, paragraph 1, and Annex IV, paragraph 1.1

Regulation: N/A

Question: Can a vehicle be supplied to the consumer with an EU CoC but in kit form?

Interpretation:

For an O1 unbraked trailer, yes.

For all other vehicle categories, no.

Even for an O1 unbraked trailer the kit must be totally complete - i.e. no other components, fasteners, or materials must be needed to assemble the vehicle to its approved form and there must be adequate assembly instructions included in the kit in the language of the country in which it is first sold. These aspects must be given particular attention during the CoP assessment.

Note: this is not a VCA decision but is a policy direction from DfT.”