Consultations

UK and European Governments and their agencies issue regular consultation documents asking for responses from stakeholders and interest groups.  We regularly respond to these consultations on behalf of our members.  We always welcome member feedback to help us with this task. Below is a list of recent consultations relevant to NFDA that we have submitted a response to or are in the process of responding to. We welcome member’s views and input into any open consultations.

CONSULTATION ON THE ENFORCEMENT OF VEHICLE TYRE LABELLING REGULATIONS

The Department for Transport has consulted on new regulations that will enforce directly applicable European Union (EU) obligations, to encourage consumers to purchase tyres that will reduce the environmental impact of motoring through reduced fuel consumption and noise. 

The RMI has responded to the consultation and has spoken with other significant trade bodies to ensure a united response has been adopted. 

New requirements for consumer labelling of tyres came into effect by means of EU regulation from November 2012.

Download PDF

 

FCA’S GENERAL INSURANCE ADD-ONS MARKET STUDY: PROVISIONAL FINDINGS AND PROPOSED REMEDIES MS14/1

The FCA conducted a study into general insurance add-ons in 2013, publishing their findings in March (2014). Interested parties were then invited to comment on the report. The NFDA has responded to the market study, assessing the findings and voicing concerns over the FCA's analysis of their main piece of data from the report; the cancellation of GAP policies.

Download PDF

 

DETAILED PROPOSALS FOR THE FCA REGIME FOR CONSUMER CREDIT: FINANCIAL CONDUCT AUTHORITY

On 1 April 2014 the Financial Conduct Authority will take over the regulation of the consumer credit industry from the Office of Fair Trading. They consulted on the detailed proposals for how they will do this.

Download PDF

 

TRANSFORMING THE HIGHWAYS AGENCY INTO A GOVERNMENT-OWNED COMPANY: DEPARTMENT OF TRANSPORT

The Department of Transport consulted on proposals for setting up the Highways Agency as a new government-owned company responsible for operating, managing and improving the strategic road network. The outcome of this consultation will inform the final form of the new company and shape the legislation needed to empower the company to run the strategic road network. This is planned for 2014.

Download PDF

 

MARKET STUDY INTO GENERAL INSURANCE ADD-ON PRODUCTS: FCA

The FCA undertook a market study into the general add-on insurance market in order to establish how the products are sold and whether competition is effective and legitimate. The study looked at whether there are common features of the add-on market that weaken competition and leave consumers worse off, taking into account how firms and consumers behave and how they interact to shape prices and the quality and take-up of products.The FCA undertook a market study into the general add-on insurance market in order to establish how the products are sold and whether competition is effective and legitimate. The study looked at whether there are common features of the add-on market that weaken competition and leave consumers worse off, taking into account how firms and consumers behave and how they interact to shape prices and the quality and take-up of products.

Download PDF

 

CONSULTATION ON THE FEES FOR HGV AND PSV TESTING, OPERATOR LICENSING AND OTHER VOSA SERVICES: VOSA

This VOSA consultation outlined proposals to changes fees for a range of services including HGV testing, operator licensing and associated services. It examines the removal of the remaining cross subsidy of VOSA test facility costs from users of ATFs and charging the cost of extra VOSA resource to service ATFs to ATF users.

The NFDA response broadly supports the VOSA proposals and any movement to move testing away from VOSA sites and nearer to the operator.

Download PDF

 

HM TREASURY: REFORMING THE CONSUMER CREDIT REGIME

This consultation document considered the merits of transferring responsibility for the regulation of consumer credit the Office of Fair Trading (OFT) to the new Financial Conduct Authority (FCA).

Download PDF

 

FINANCIAL CONDUCT AUTHORITY: CONSUMER CREDIT REGULATION, OUR PROPOSED REGIME

This paper, which is being published by the Financial Services Authority (FSA) because the FCA will not exist until 1 April 2013, should be read together with the Government’s consultation document. It describes how we propose that the FCA will carry out its new functions and use the powers that the Government plans to give it, taking account of its strategic and operational objectives, including to promote effective competition in the interests of consumers.

Download PDF

 

CONSULTATION ON ENHANCING CONSUMER CONFIDENCE BY CLARIFYING CONSUMER LAW: DEPARTMENT OF BUSINESS, INNOVATION AND SKILLS

The coalition government has embarked on a programme of consumer law reform; for the benefit of consumers, traders and general business practice, creating a Consumer Bill of Rights. The RMI has submitted a detailed response to the proposals. The main objectives of the consultation are; clarification and simplification of existing consumer law, the rights of consumers and the obligations of traders in the supply of goods, services and digital content. The RMI endorses the overall aims of the paper but has vocalised concern with some proposals concentrated heavily on repair and refund and reduction for use policies. The RMI has stressed the importance of neutrality within any developed legislation and the need for flexibility to account for complex and unforeseen circumstances inevitable within business practice. 

Download PDF

 

NFDA RESPONSE TO TFL ULTRA LOW EMISSIONS ZONE CONSULTATION

The Mayor of London is proposing to create an ultra low emission zone where almost all the vehicles running during working hours are either zero or low emission. A public consultation on the ULEZ took place between 27 October 2014 and 9 January 2015. This includes proposals to introduce a vehicle emissions charging scheme in central London, alongside proposals for buses and revised taxi and Private Hire Vehicle licensing requirements. 

The NFDA has placed great emphasis on the need for any standards to be consistent with technological developments.

Download PDF

 

NFDA RESPONSE TO THE HMRC VAT RELIEF ON SUSTANTIALLY AND PERMANENTLY ADAPTED MOTOR VEHICLES FOR DISABLED WHEEL CHAIR USERS

This consultation required views on proposals to reform the VAT relief within European law; specifically, reform of the VAT zero rate relief on motor vehicles that have been substantially and permanently adapted for use by a disabled wheelchair user.

Within the NFDA's response, praise was given to HMRC for engaging in consultation and reform in this VAT relief area and stated our availability for further cooperation, if so required, at a later date. The NFDA is in agreement that there is a need to reform the relief for substantially and permanently adapted motor vehicles for disabled wheelchair users, stating in the response, that many franchised dealers have found the exemption (in its current form) complex and difficult to use, having huge concern about their ability to comply with the rules.

Download PDF



NFDA RESPONSE TO THE HMRC EMPLOYEE BENEFITS AND EXPENSES CONSULTATION

NFDA response to the HMRC Employee Benefits and Expenses Consultation: Real time collection of tax on benefits in kind and expenses through voluntary payrolling.

In his 2014 Budget the Chancellor of the Exchequer announced that, in response to the recommendations of the Office of Tax Simplification (OTS), the government would launch a package of 4 related consultations on employee benefits in kind and expenses, alongside a longer term review of the tax treatment of travel and subsistence expenses, and a call for evidence on modern remuneration practices.

The government launched these 4 consultations and the call for evidence on 18 June 2014.

These measures are focused on reducing the administrative burdens relating to benefits in kind and expenses for employers, individuals and HMRC.

The NFDA responded to the above consultation and is in full support of a voluntary payrolling framework. In the response, the NFDA placed great emphasis that the framework would undoubtedly need to be voluntary and that once a business’s commits to this framework, this should be sustained unless in the case of exceptional or unforeseen circumstances or significant changes occur to a businesses, granting the voluntary scheme impractical or unmanageable.

Download PDF



NFDA RESPONSE TO THE DTF’S CONSULTATION INCREASED SPEED LIMIT FOR HEAVY GOODS VEHICLES OVER 7.5 TONNES:DUAL CARRIAGEWAYS

The Department for Transport invited views on a proposed maximum speed limit increase for heavy goods vehicles, over 7.5 tonnes, when travelling on dual carriageway roads. In the proposal, the speed limit would increase from the current 50 miles per hour to 60 miles per hour.

The consultation was published in July 2014 and the NFDA responded in full support of the limit increase.

The NFDA stated the following in the response executive summary:
The NFDA fully endorse the proposal to increase the speed limit for HGVs over 7.5 tonnes on dual carriageways to 60mph. It is undisputable that the majority of commercial vehicle drivers exceed the current limit of 50mph. As governors are set at 56mph, this enables drivers to reach a higher speed than the 50mph limit, allowing commercial drivers to bring their vehicles speed to a similar level as other road users. This creates a level of consistency to the flow of traffic and, in fact, creates a safer driving environment as a result. The NFDA therefore believes that this is the next logical step within the series of reform the DfT are currently undertaking.

Download PDF



NCS SUBMISSION TO ALTERNATIVE DISPUTE RESOLUTION FOR CONSUMERS

The National Conciliation Service ('NCS') has responded to the above BIS consultation paper and the submission is supported by the RMI associations. The consultation is seeking views on the proposals for applying the requirements of the European Directive on Alternative Dispute Resolution (ADR) (2013/11/EU) and the Regulation on Online Dispute Resolution (ODR) (524/2013) into UK law.  

The new requirements aim to give European consumers greater access to redress, outside of court, should something go wrong with their bought goods or services. The consultation will also look to reform consumer ADR beyond the remit of the Directive.

Download PDF



RMI RESPONSE TO CONSULTATION ON THE ENFORCEMENT OF VEHICLE TYRE LABELLING REGULATIONS

The Department for Transport has consulted on new regulations that will enforce directly applicable European Union (EU) obligations, to encourage consumers to purchase tyres that will reduce the environmental impact of motoring through reduced fuel consumption and noise.

The RMI has responded to the consultation and has spoken with other significant trade bodies to ensure a united response has been adopted.

New requirements for consumer labelling of tyres came into effect by means of EU regulation from November 2012.

Download PDF



NFDA RESPONSE TO FCA’S GENERAL INSURANCE ADD-ONS MARKET STUDY: PROVISIONAL FINDINGS AND PROPOSED REMEDIES MS14/1

The FCA conducted a study into general insurance add-ons in 2013, publishing their findings in March (2014). Interested parties were then invited to comment on the report. The NFDA has responded to the market study, assessing the findings and voicing concerns over the FCA's analysis of their main piece of data from the report; the cancellation of GAP policies.

Download PDF