Registration of amateur built kitcars and kit-conversions.

Part 3          Kits that retain the donor CHASSIS

 SAMPLE DOCS TO FOLLOW

In part 2, we looked at “kit conversions” (“DVLA-speak” for “donor-built” kitcars) i.e. those based on at least some second-hand components from a donor vehicle. The third type of “kitcar” is one where the vehicle retains the donor vehicle’s complete, unmodified chassis or monocoque body.  This is the most straightforward case because as far as the DVLA are concerned, it is the same car.  The key word here is “unmodified”. Up until January 2001, this word was missing and this lead to some pretty dramatic modifications escaping SVA. In an effort to reduce the number of vehicles slipping through the net, the DVLA altered the wording in its “INF 26” document to say, “original, unmodified chassis or unaltered monocoque bodyshell”. Click Here to see both sides of the DVLA’s INF 26 leaflet entitled  “Guidelines for the registration of rebuilt or radically altered vehicles and kitcars”. This now means that there are precious few kits which can genuinely retain the donor registration and escape SVA. Good examples might be the “Dakar” 4x4 based on a Range Rover chassis, various kits based on the American Pontiac Fiero or the Lomax 224 based on the Citroen 2CV chassis. VW Beetle-based kits, on the other hand, need treating with caution. Many beach buggies, for example, use a shortened Beetle floorpan and while this might be perfectly safe in engineering terms (if done properly) it could certainly not be regarded as being “unaltered”. The truth of the matter is that donor cars with separate chassis are becoming rarer. Once, there would have been a broad range of kits based on the Triumph Herald but now, Heralds are becoming rare and collectable in their own right.

Obviously, the lure of being able to escape an SVA test is strong and this has resulted in some manufacturers trying to claim that all sorts of things should constitute a “chassis”. For the record, we at totalkitcar believe a chassis to be a single, continuous, frame to which suspension and drive train are attached and which is capable of adequately withstanding “in-service” loads without any additional reinforcement. This means that a “chassis” is NOT both subframes from a donor car. Similarly, it is NOT, the floorpan cut out of a sheet steel monocoque car!  In general, a good test of whether or not the vehicle has a chassis is to see if you can remove the body without cutting anything – merely removing mechanical fasteners AND see that the bit with the engine and suspension still attached to it is a one-piece structure.

Having said all that, it must also be said that the decision as to whether or not the original unaltered chassis has been used rests with your DVLA Local Office. Regardless of the engineering implications, if you can convince them it’s a chassis, then a chassis it is!

Once you have established that your kit does, indeed retain the unaltered donor chassis the steps you need to take and the paperwork that must be completed are outlined below. It is also important to understand that this article outlines the registration procedure as we at totalkitcar.com see it.  Due to the great degree of autonomy that the DVLA has allowed its Vehicle Registry Offices, many of them will tailor the process of applying for a registration document to suit their own systems of working. Accordingly, don’t be distressed if your particular registration doesn’t go exactly according to the procedure laid down here. If, however, you do feel you have been unfairly treated, please get in touch and we will do our best to help!

Another very important point is that the DVLA are likely to be reviewing their policy towards donor-built kits in the next few months. This is likely to lead to changes being implemented so please keep checking the site throughout your build! We will publish any changes to the requirements as soon as we hear of them.

The first thing you need (at the risk of sounding too obvious!) is a donor chassis. Seriously, very few vehicles these days truly have a chassis so your choices are limited. Many of those that do are, themselves rare and collectable (Lotus, TVR etc) so there’s not much chance of getting one of these. Why am I saying this? Well, really to highlight the fact that Vehicle Registration Offices don’t expect to see many cars with a donor chassis so you should expect to be examined thoroughly when you present your case.

You then need to update the donor’s V5C document. Remember that effectively, the DVLA will treat a kit car with a donor chassis as still being the donor car but with a different body on it.  Accordingly, they would expect to see the V5C for the donor returned to them for updating.  The recorded vehicle details on the new-style V5Cs appear in Section 4. Any changes to the vehicle should be recorded by you in section 7 of the V5C. Click Here to see a completed sample V5C for a donor-chassis kitcar.

It is worth mentioning at this point that the V5C document has changed. Everyone who has bought, sold, taxed, declared as “SORN” (Statutory Off Road Notification) or modified a vehicle in the last year or so should already have received a “new-style” V5C. This is a large, A4 sized 4-sided document, which is now standardised across all EC Member States. At the time of writing, the DVLA is doing one last sweep of all the vehicles on their computer to try and catch any vehicles that still have the old-style V5. For the most part, the vehicles that will not have the new-style documents will be those that were not taxed (i.e. off the road) before 1998. It is very important that you get your donor a new-style V5C before you turn the car into a kit. Phone your DVLA Local Office for more details. You should be sent a new-style registration document and it is this document that you should make the changes on. Note that from June 2006, the old-style documents will cease to have any legal value.

Depending on what you do to the car, you will have to write the changes in the boxes provided next to each entry. The first item is “Wheelplan / Body type”. You might retain the same wheelplan (usually “2-axle rigid body” for most 4-wheeled cars) or you might alter one or both (such as by turning a Citroen 2CV chassis into a three-wheeler chassis for a Lomax or Blackjack). Similarly, you might well change the body type from a “4 door saloon” to a “convertible”. Whatever you do, simply write the new descriptions in the boxes. Lists of recognised wheelplans and body types are published in Appendices “G” and “H” of the DVLA’s booklet, V355, entitled “Guidance Notes for the Completion of V55 forms” Click here to see a copy of Appendix “G” (Body codes) and Click Here to see a copy of Appendix “H” (Wheelplan codes). 

The next item is the “VIN/Chassis/Frame number.” THIS MUST NOT CHANGE. If you change this, you are effectively creating another vehicle and, in doing so, you will have to undergo an SVA test and you might end up with a “Q” plate if you haven’t used enough components from the donor! 

The next entry relates to “Revenue Weight”. This only relates to goods vehicles so it is unlikely to change for most kitcars. 

The next field (Field 24) is the cylinder capacity. If the engine capacity changes, write the new capacity in the appropriate box. It is worth noting that your local Vehicle Registration Office may want documentary proof of the new engine’s capacity because if (for example) it is smaller than the original capacity stated on the donor’s V5C, the car may become eligible for less road tax. They might also want to inspect the vehicle. It is up to the individual office concerned to say exactly what proof they require but generally, a copy of the V5C from the vehicle that the engine was taken (not your donor) would be useful to keep with all the other build documents.

If the number of seats has changed (say from 4 to2), note the change in field No. 25. The number of standing places (field 26) does not apply to cars.

Field 28 is for the engine number. If you fit a different engine, write the new engine number next to the old one in the space provided. 

Often, however, the vehicle’s colour changes. If it has, write the new colour in the space provided. The DVLA have only 19 colours on their computer that they can use to describe a vehicle. These are listed in Appendix “I” of the V355 booklet. If your vehicle happens to be painted in “Saharan Sandglow Passion”, just call it  “yellow” or “orange” – whichever is closest.  It might not have the same panache, but it makes everyone’s life easier!  Click here for the complete list. 

While you are updating the V5C, it is ESSENTIAL that you also change the vehicle make and model. You may have read a great deal in the kit car press about the potential problems associated with having an incorrectly registered kit (i.e. a kit that is still registered as the donor vehicle) so this step is absolutely vital. You will also notice that there is no space on the V5C to amend these details so the DVLA’s advice is that you send a covering letter along with your amended V5C. This letter must clearly state the new vehicle details. Click Here to see a sample letter – feel free to use the same format with your own vehicle details if you wish.

The amended V5C, together with the covering letter must then be sent to the DVLA in Swansea.  The address is:

DVLA,

Swansea,

SA99 1BA.

In due course, you should receive a letter from Swansea asking you to make an appointment to have the vehicle inspected by your local Vehicle Registration Office. This doesn’t always happen because sometimes, the DVLA doesn’t feel that the modifications are serious enough to warrant an inspection.  If this is the case with your kit, you will receive an amended V5C through the post and the matter will end there!  If they DO think it needs inspecting, read on. The purpose of this inspection will be to check that the vehicle is how it was described in your letter and amended V5C. Some Vehicle Registration Officers will visit you at the place where the vehicle is kept, others will insist on it being brought to the DVLA Local Office (remember to confirm whether or not they will allow you to drive it on the road at this stage!) and others use the local police to carry out the inspection. You might be asked to fill in a Built-Up Vehicle inspection form.

The “Built Up Vehicle Inspection Report” – form V627/1, is often filled in by the Vehicle Registry Office Inspector when the car is inspected. The form is pretty straightforward but if you have to fill your own in, the following notes may be helpful:

The “Present Registration Mark” box in the top right-hand corner, will obviously contain the donor’s registration number. Remember that the make and model of the vehicle are NOT those of the donor vehicle. If the car is a “Lomax”, for example, you must put this on the form and NOT “Citroen” (or whatever the donor was). 

To see an example of the Built-up Vehicle Inspection form (V627/1) for a donor-built kit car that retains the donor CHASSIS, click here. Note that the example is for a kit based on an Alfa Romeo 164 chassis. The more alert readers among you will have spotted that Alfa 164s do NOT actually have a separate chassis but this was the only V5C document readily to hand at the time of writing! For the colour and taxation class, use the same colour and taxation class as you wrote on the V5C. NOTE: The year of manufacture will be the year the donor was built (e.g. 1988) and NOT the current year. If the car is currently licensed, tick the “yes” box on the form. If not, tick the “No” box.

The rest of the V627/1 form consists of a table showing where each of the major components came from. Remember that in order to retain the donor registration (and escape SVA), you need to use the original, unmodified chassis AND at least TWO major components from the donor. These could be: 

Engine,

Transmission,

Suspension (both ends)

Axles (both ends)

Steering assembly.

Failure to prove this will result in the allocation of a “Q” plate!

Precisely what constitutes an “axle” or “suspension” these days, is highly open to interpretation and the final decision rests with the DVLA Local Office although an appeals procedure does exist.

Returning to the table on the V627/1 form, if, for instance, the engine came from the donor vehicle, they would expect to see the engine number in the first column, the donor’s registration number in the second column, the donor’s make in the third column and a tick or cross in the fourth column depending on whether the receipt was available. Obviously, it would be a good idea to keep the donor’s V5C (or a copy if you have sold or scrapped the vehicle) showing that engine number as further evidence. In the example shown, the donor engine has NOT been used, consequently, the engine number is different to that on the original V5C.

If you used (say) the steering assembly from the donor vehicle, there will obviously be no serial number to record but the other three columns can be filled in.

If you have bought a reconditioned (say) transmission, and it didn’t come out of the donor, you must write “reconditioned” in the column marked “origin”. Note that if the donor vehicle happened to have been fitted with a reconditioned transmission before it was broken up to use as a donor, you would still regard the transmission as coming from the donor even though it is not necessarily the transmission the car was built with. If the transmission was new or second-hand but not from the donor, you should write either “new” or “second hand” in this column.  Obviously, receipts to support your claims would be essential.

If you are building a car with a motorcycle engine, you put the engine number and donor registration (if you have it) in the top table and not the lower one. The form relates to the built up CAR that you have completed. NOT the donor that you have raided for parts. Obviously, if you are building a kit motorcycle, you use the bottom table.

Finally, you must state how you disposed of the rest of the donor vehicle. In most cases, this will be by taking it to a scrap yard.

The last thing you will need is, of course, an MOT certificate – assuming the donor was more than 3 years old. You are allowed to drive the car to and from a pre-booked MOT test before it is registered and taxed provided you have adequate insurance cover. Check with your insurers.

To summarise then:

1.         Find your donor vehicle with its separate chassis. Make sure the chassis or VIN code on the vehicle you buy is the same as the one on its V5C Registration document.

2.         Make sure you have the new-style “V5C” registration document for the donor – not the old V5.

3.         Do your conversion. Remember that you must use the “original and unmodified” donor chassis AND at least TWO major components from the same car.

4.         Fill in the amendments on the base vehicle’s V5C (e.g. engine number and capacity, colour, body type etc.)

5.         Take the vehicle for an MOT test.

6.         Send the amended V5 to the DVLA along with a covering letter asking them to change the vehicle make and model.

7.         When told to by Swansea, take the vehicle to your local Vehicle Registration Office along with its MOT. You may need to complete the Built Up Vehicle inspection form V627/1.