people that offer assistance to consumers in the UK, who wish to import an American vehiclenot offered for sale by the manufacturers in Europe. We are typical of similar businesses allover Europe. Our members also provide or arrange servicing, parts supply, warranties andother facilities offered by a car dealer to ensure compliance with the legal obligations relatingto consumer protection. As the vehicles are not imported by the manufacturers, we display anextra duty of care to look after the consumer, and often receive referrals from themanufacturers customer service help-lines in the UK to deal with customer queries. The AIAAis recognised by the UK Government as a legitimate stakeholder in the Motor Trade and is anactive member of DfT’s Light Vehicle Trade User GroupMost of the cars imported are new vehicles ordered in advance by a consumer who wants todrive an unusual vehicle. The vehicles do not undermine the Type Approval system, as thevolumes imported are extremely low, and they are mainly bought by enthusiasts. NewAmerican vehicles have been independently imported into Europe for over 50 years. Thesevehicles are not built to European standards, but are built to broadly equivalent Federal or Canadian safety and environmental standards. To register a vehicle in a Member State, eachvehicle has to be submitted to a National homologation process called Individual vehicleApproval (IVA). As it says in the Commission’s Interpretative communication on proceduresfor the registration of motor vehicles originating in another Member StateSEC/2007/0169,“National type-approval and individual approval procedures for motor vehicles to be used or registered for the first time in the EU normally fall outside the scope of EC law.”This micro-industry supports a whole infrastructure of specialist businesses and dozens of specialist car clubs. (
See attachment 1-Paper on American Vehicles in the UK)
Unless thedraft proposal is withdrawn, there are literally hundreds of thousands of European citizenswhose lives will be adversely affected without a compelling justification. The draft regulationsare only aimed at
vehicles (defined as mass produced vehicles under 6 months old),indicating the discriminatory and anti-competitive nature of the draft proposal.In the UK, there are currently less than 500 new American vehicles imported each year,comprising dozens of different models. This compares to circa 2.25 million new passenger cars(M1) and light commercial vehicles (N1) that the SMMT’s members will register in the UKin 2009. In the 27 Member States during 2009, we estimate that for M1 and N1 vehicles,38,000 new vehicles will have used National IVA schemes out of a total new vehicleregistration figure of 16.1 million vehicles-i.e. 0.24 percent. (Source ACEA website) In other words, the ACEA’s members will have accounted for 99.76% of all new Passenger Car andLight Commercial vehicles sold in Europe in 2009. In 2010, can the European consumer notenjoy any choice beyond what the manufacturers have planned for him/her to purchase?With these draft Harmonised regulations, the Commission seems to have grossly over-reacted to a case from a few years ago where 300 allegedly unsafe identical ChineseLandwind vehicles were unwisely approved by a rubber-stamp method in Germany. This hasled to an intensive lobbying campaign from the FIA to restrict any vehicles that did not haveEuropean type approval, a process only available to manufacturers. (
See attachment 2 -Statement from the FIA-Loophole in the European Type Approval?
). This inappropriatemethod of rubber-stamping approval is not in the spirit of single vehicle approval and is not