{ "licence": "MODUWRIGHT open reference data. Free to reproduce, in whole or in part, commercially or otherwise, on one condition: name the source and link to http://127.0.0.1:8812/standards/evidence. Every row is a verified external fact read from the regulator or the instrument on the date given. It is not legal advice. Corrections: http://127.0.0.1:8812/research/corrections", "verified_at": "2026-09-04", "source": "http://127.0.0.1:8812/standards/evidence", "bands": [ { "id": "at-manufacture", "title": "True at manufacture, or never", "lede": "These cannot be added, corrected or certified after the unit is built. A unit that leaves the floor without them does not become compliant later, it becomes unsaleable, and the loss falls on whoever is holding it.", "kind": "gate", "rows": [ [ "Australia", "Gas appliance certification", "An authorised Conformity Assessment Body", "Certification must exist at the time of manufacture and cannot be added later. CE and CSA certification are explicitly not sufficient. It is an offence in every state and territory to sell or offer an uncertified Type A appliance." ], [ "New Zealand", "Gas appliance and fitting certification", "A recognised certification body", "Gas appliances and specified fittings must be certified before being offered for sale, and the importer must make a Supplier Declaration of Compliance." ], [ "United States", "Part 567 certification label", "The original manufacturer", "A conforming trailer is admitted on a declaration with no government approval only if the certification label was permanently affixed by the original manufacturer. Without it the fallback route needs a Registered Importer and a bond of 150 percent of dutiable value." ], [ "Canada", "Bilingual Canadian compliance label", "The original manufacturer", "The trailer must be built to CMVSS and carry the label affixed at manufacture. CBSA D19-12-1 states there is no provision to modify a non-compliant vehicle into compliance after import, and it cannot be brought in for parts either." ], [ "Australia and generally", "17 character VIN under a World Manufacturer Identifier", "The WMI is allocated to the manufacturer", "The identifier is struck into the unit and recorded on the statutory plate. Restriking a VIN is not a correction, it is a defect in the identity of the vehicle." ] ] }, { "id": "before-shipment", "title": "In place before the unit ships", "lede": "These bind the movement rather than the build. A unit that sails without them is a unit sitting under customs control at the far end, accruing storage, with no route forward that does not involve sending it back.", "kind": "gate", "rows": [ [ "Australia", "Import approval under section 22, Road Vehicle Standards Act 2018", "The Commonwealth department", "It is an offence to import a road vehicle without approval and the Australian Border Force will not release an unapproved vehicle from customs control. Assessment takes up to 60 business days, so it is planned against the build rather than against the sailing." ], [ "Australia", "Concessional entry headroom", "The Commonwealth department", "Concessional entry to the Register of Approved Vehicles is capped at four low ATM trailers of 4.5 tonnes or less per twelve months, and a single vehicle import application is itself capped at four trailers. Above that a vehicle type approval is required, which is a different route with a different lead time." ], [ "United States", "Designated US agent for service of process", "Designated with NHTSA by the manufacturer, assembler or importer", "49 CFR 551.46 requires the designation before a vehicle is offered for import. It is a filing rather than an approval, and it is the step most often discovered too late." ], [ "United States", "EPA Form 3520-21 for an onboard engine", "Filed with CBP, against a valid EPA certificate of conformity", "A generator on the unit is a separate federal requirement from the trailer. Admission needs the form and a valid certificate for that engine." ], [ "Canada", "VIN specific case by case authorisation", "The Canadian authority, to the importer", "An importer buying directly from a foreign manufacturer not listed on Appendix G obtains authorisation per VIN, and the unit must be purchased directly at the manufacturing level." ] ] }, { "id": "before-supply", "title": "In place before the unit is supplied", "lede": "The unit can be in the country and still not lawfully change hands. In two of these markets supplying without the certificate is a criminal offence rather than a paperwork problem.", "kind": "gate", "rows": [ [ "Great Britain", "An EU Certificate of Conformity, a national small series certificate, or an IVA certificate", "The manufacturer, the approval authority, or DVSA", "Under the Road Vehicles (Approval) Regulations 2020, Schedule 4 paragraph 1(1), supplying a recordable trailer for use on a road without one in effect is an offence. Penalty is an unlimited fine in England and Wales, or up to three months imprisonment for an individual, or both." ], [ "Great Britain", "DVSA consent for a large trailer", "DVSA, before supply", "Regulation 23 requires the supplier to notify DVSA, provide the pertinent information and obtain consent before supply. DVSA may inspect and test, and consent is withheld until import VAT and customs duty are paid. Large trailer is defined in regulation 26 by unladen weight over 1,020 kg or any semi-trailer, for trailers built to carry goods, and not by the 3,500 kg line." ], [ "Australia", "Entry on the Register of Approved Vehicles", "The Commonwealth department", "Every trailer must be on the register before it is first provided to an Australian consumer." ], [ "Netherlands", "Approval before it is driven or sold", "RDW", "The RDW states the vehicle must be approved before it may be driven or sold, and Article 48(1) of Regulation (EU) 2018/858 conditions making available on the market on approval. The requirement binds selling, not only registering." ] ] }, { "id": "before-registration", "title": "In place before the unit is registered", "lede": "The unit is lawfully in the country and lawfully sold, and it still cannot be driven. These steps happen at the destination, they are the buyer's or the importer's to arrange, and they take time that has to be in the plan rather than discovered in it.", "kind": "route", "rows": [ [ "Germany", "Gutachten from an amtlich anerkannter Sachverstaendiger or a designated Technical Service", "At the applicant's expense", "National individual approval under Article 45 of Regulation (EU) 2018/858 is granted by the competent Land authority rather than by the KBA. There is no EU wide individual approval fallback for this product." ], [ "Germany", "Compliance with Regulation (EU) 2019/2144, General Safety Regulation II", "Evidenced within the Article 45 procedure", "Since 7 July 2026 the German Article 45 procedure requires it for categories O1 and O2. The applicable requirement set for a given category is the open question on this market and it is recorded as open rather than assumed." ], [ "Netherlands", "Physical inspection after arrival", "RDW", "Without original vehicle documents or a CoC the RDW asks for documentation on coupling and drawbar, brakes, steering and underrun protection, and states that approval is less certain." ], [ "France", "Individual or isolated reception", "The regional authority", "Required before registration." ], [ "New Zealand", "Warrant of Electrical Fitness to AS/NZS 3001.2", "An inspecting electrician", "Electricity (Safety) Regulations 2010 regulation 76 bars connecting a connectable installation in a vehicle to a supply without a current warrant. Trailers under 3,500 kg are otherwise VIN exempt and need no entry certification." ] ] }, { "id": "after-supply", "title": "Obligations that continue after the unit is delivered", "lede": "Two of these bind a legal entity rather than a vehicle, which means they cannot be discharged by the factory and cannot be discharged by an offshore seller either.", "kind": "route", "rows": [ [ "Great Britain", "Ten year supply record", "Kept by the final supplier", "Regulation 25(3) obliges the final supplier to keep a record of each small trailer supplied for not less than ten years. Breach is its own offence, separate from the supply offence." ], [ "Australia", "EESS Responsible Supplier registration", "The first importer", "Under the Electrical Equipment Safety System the first importer is the Responsible Supplier and must be an Australian or New Zealand legal entity with an ABN or NZ IRD number. An overseas company cannot register." ], [ "Netherlands", "Business stock recognitions", "RDW erkenning Bedrijfsvoorraad and TVBI", "Holding trailers in Dutch business stock and registering them in the company's own name requires both, which require establishment in the Netherlands. Registration by the end customer or a recognised Dutch dealer avoids the requirement." ] ] } ], "changes": [ { "date": "2026-07-07", "market": "Germany", "state": "in force", "title": "German Article 45 individual approval now requires General Safety Regulation II compliance for O1 and O2", "instrument": "Regulation (EU) 2019/2144, within the Article 45 procedure of Regulation (EU) 2018/858", "what": "The German national individual approval procedure for trailer categories O1 and O2 now requires compliance with the General Safety Regulation. The procedure is run by the competent Land authority rather than by the KBA, and it is evidenced by a Gutachten from an officially recognised expert or a designated Technical Service, at the applicant's expense.", "who": "Anybody building, importing or individually approving a trailer up to 3.5 tonnes for German registration.", "open": "The applicable requirement set for these categories is not yet established to source. It is recorded as open rather than assumed.", "source_ref": "countries.json, Germany, verified 2026-09-04", "sources": [ { "title": "Regulation (EU) 2019/2144, the General Safety Regulation", "url": "https://eur-lex.europa.eu/eli/reg/2019/2144/oj/eng", "read": "2026-09-08" }, { "title": "Regulation (EU) 2018/858, Article 45", "url": "https://eur-lex.europa.eu/eli/reg/2018/858/oj/eng", "read": "2026-09-04" } ], "binds": "The person applying for approval, which is the importer or the builder, not the operator", "asks": "Evidence at approval rather than a change to the unit. A Gutachten from a recognised expert or a designated Technical Service, at the applicant's expense.", "nations": "Germany", "kind": "vehicle" }, { "date": "2026-01-01", "market": "Great Britain", "state": "in force", "title": "Supplying a category O trailer without a certificate in effect is an offence, and large trailers need DVSA consent first", "instrument": "Road Vehicles (Approval) Regulations 2020, Schedule 4 paragraph 1(1), and regulations 23, 25(3) and 26", "what": "Supplying a recordable trailer for use on a road without an EU Certificate of Conformity, a national small series certificate or an IVA certificate having effect is a criminal offence. Penalty is an unlimited fine in England and Wales, or up to three months imprisonment for an individual, or both. For a large trailer, defined by unladen weight over 1,020 kg or any semi-trailer built to carry goods, regulation 23 requires the supplier to notify DVSA, provide the pertinent information and obtain consent before supply. Consent is withheld until import VAT and customs duty are paid. Regulation 25(3) separately obliges the final supplier to keep a record of each small trailer supplied for at least ten years.", "who": "Anybody supplying a new trailer for road use in Great Britain, including an importer selling direct.", "open": "", "source_ref": "countries.json, United Kingdom, verified 2026-09-04", "sources": [ { "title": "The Road Vehicles (Approval) Regulations 2020", "url": "https://www.legislation.gov.uk/uksi/2020/818/contents", "read": "2026-09-08" } ], "binds": "Anybody supplying a new trailer for road use, including an importer selling direct", "asks": "A certificate in effect before supply, and for a large trailer, DVSA consent obtained first. Neither can be added after the sale.", "nations": "Great Britain", "kind": "vehicle" }, { "date": "2025-07-01", "market": "Australia", "state": "in force", "title": "Concessional entry to the Register of Approved Vehicles is capped at four trailers per twelve months", "instrument": "Road Vehicle Standards Act 2018", "what": "Concessional entry to the Register of Approved Vehicles is capped at four low ATM trailers of 4.5 tonnes or less per twelve months, and a single vehicle import application is itself capped at four trailers per application. Above that a vehicle type approval is required, which is a different route with a different lead time. Import approval under section 22 must exist before the unit ships and assessment takes up to 60 business days.", "who": "Any importer bringing more than four trailers into Australia in a rolling year, which includes every hire fleet and every dealer.", "open": "", "source_ref": "countries.json, Australia, verified 2026-09-04", "sources": [ { "title": "Low-ATM trailers, Department of Infrastructure", "url": "https://www.infrastructure.gov.au/infrastructure-transport-vehicles/vehicles/rvs/low-atm-trailers", "read": "2026-09-04" }, { "title": "Concessional RAV entry approvals", "url": "https://www.infrastructure.gov.au/infrastructure-transport-vehicles/vehicles/importing-vehicle/concessional-rav-entry-approvals", "read": "2026-09-04" } ], "binds": "The importer holding the concessional entry approval", "asks": "Nothing about the unit. It caps how many units may enter by that route, which is a business constraint rather than a specification one.", "nations": "Australia", "kind": "vehicle" }, { "date": "2025-01-01", "market": "Australia", "state": "in force", "title": "Gas appliance certification must exist at manufacture and cannot be added afterwards", "instrument": "State and territory gas safety legislation, via an authorised Conformity Assessment Body", "what": "It is an offence in every state and territory to sell or offer a Type A gas appliance not certified by an authorised Conformity Assessment Body. Certification must exist at the time of manufacture and cannot be added later. CE and CSA certification are explicitly not sufficient.", "who": "Any manufacturer building a unit with gas cooking or gas water heating for the Australian market, and any importer buying one.", "open": "", "source_ref": "countries.json, Australia, verified 2026-09-04", "sources": [ { "title": "Energy Safe Victoria, gas appliances and online sales", "url": "https://www.energysafe.vic.gov.au/industry-guidance/gas-and-pipelines/gas-appliances-equipment-and-manufacturers/gas-appliances-online-sales", "read": "2026-09-04" } ], "binds": "Whoever sells or offers the appliance, which reaches the unit's builder", "asks": "Certification for the destination market held at the time of manufacture. CE and CSA are explicitly not sufficient, so the appliance is chosen before the unit is built or not at all.", "nations": "Australia", "kind": "vehicle" }, { "date": "2025-01-01", "market": "Australia", "state": "in force", "title": "The first importer is the Responsible Supplier and must be an Australian or New Zealand legal entity", "instrument": "Electrical Equipment Safety System", "what": "Under the Electrical Equipment Safety System the first importer is the Responsible Supplier and must be an Australian or New Zealand legal entity with an ABN or NZ IRD number. An overseas company cannot register.", "who": "Any offshore seller intending to import into Australia in its own name. The obligation attaches to an entity, so it cannot be discharged by the factory or by a foreign seller.", "open": "", "source_ref": "countries.json, Australia, verified 2026-09-04", "sources": [ { "title": "EESS, manufacturers and importers as Responsible Suppliers", "url": "https://www.eess.gov.au/responsible-supplier/manufacturers-and-importers-responsible-suppliers/", "read": "2026-09-08" } ], "binds": "The first importer of in scope electrical equipment", "asks": "An entity, not a change to the unit. An overseas company cannot register, so somebody local has to hold it.", "nations": "Australia and New Zealand", "kind": "vehicle" }, { "date": "2025-01-01", "market": "Canada", "state": "in force", "title": "A non-compliant vehicle cannot be modified into compliance after import, and cannot be imported for parts", "instrument": "Motor Vehicle Safety Act, and CBSA memorandum D19-12-1", "what": "A new non-CMVSS-compliant trailer built for a market other than the United States or Mexico is inadmissible. CBSA D19-12-1 states there is no provision in the Act or the Regulations to modify a non-compliant vehicle into compliance after import, and that it cannot be brought in for parts either. The trailer must be built to CMVSS and carry a bilingual Canadian compliance label affixed by the original manufacturer, and be purchased directly at the manufacturing level.", "who": "Anybody considering Canada as a destination for a unit built to a European or Australian specification.", "open": "", "source_ref": "countries.json, Canada, verified 2026-09-04", "sources": [ { "title": "CBSA Memorandum D19-12-1, importing vehicles into Canada", "url": "https://www.cbsa-asfc.gc.ca/publications/dm-md/d19/d19-12-1-eng.html", "read": "2026-09-08" }, { "title": "Motor Vehicle Safety Act", "url": "https://laws-lois.justice.gc.ca/eng/acts/M-10.01/page-1.html", "read": "2026-09-04" } ], "binds": "Anybody considering Canada as a destination for a unit built to a European or Australian specification.", "asks": "", "nations": "Canada", "kind": "vehicle" }, { "date": "2025-01-01", "market": "United States", "state": "in force", "title": "A US agent for service of process must be designated before a vehicle is offered for import", "instrument": "49 CFR 551.46, and 49 CFR 591.5(b)", "what": "Every foreign manufacturer, assembler and importer must designate a US permanent resident agent for service of process with NHTSA before offering a vehicle for import. A conforming trailer is then admitted on a declaration with no government approval, but only if the certification label was permanently affixed by the original manufacturer. The fallback route under 591.5(f) needs a Registered Importer and a bond of 150 percent of dutiable value. An onboard generator is a separate federal requirement: EPA Form 3520-21 must be filed with CBP against a valid certificate of conformity for that engine.", "who": "Any foreign manufacturer or importer supplying a trailer into the United States, and anybody fitting a generator to one.", "open": "", "source_ref": "countries.json, United States, verified 2026-09-04", "sources": [ { "title": "49 CFR Part 591, importation of vehicles", "url": "https://www.ecfr.gov/current/title-49/subtitle-B/chapter-V/part-591", "read": "2026-09-04" }, { "title": "49 CFR Part 551 Subpart D, agent for service of process", "url": "https://www.ecfr.gov/current/title-49/subtitle-B/chapter-V/part-551/subpart-D", "read": "2026-09-04" } ], "binds": "Every foreign manufacturer, assembler and importer", "asks": "A designated agent held before the unit is offered, and a certification label applied permanently at manufacture. The label cannot be applied later.", "nations": "United States", "kind": "vehicle" }, { "date": "2027-03-31", "market": "England", "nations": "England", "state": "in force from", "kind": "operation", "title": "The micro firm exemption from workplace recycling separation ends", "instrument": "Simpler Recycling in England, workplace recycling", "binds": "Every workplace with fewer than ten full time equivalent employees, which is most single unit operators", "asks": "Separation at the point the waste is produced, food waste included, which is a question about how many containers a unit carries and where they live rather than about the trailer's construction. A unit specified with one bin has to find room for more.", "what": "Workplace recycling separation came into force in England on 31 March 2025 and micro firms, meaning fewer than ten full time equivalent employees, have until 31 March 2027. All workplaces must separate waste before collection, including waste produced by employees, customers and visitors, and food waste must always be separated. The guidance names construction sites explicitly, including food and packaging waste from contractors on site.", "who": "Micro firms in England, and any construction site receiving contractors' food and packaging waste.", "open": "", "source_ref": "gov.uk, Simpler Recycling workplace guidance, read 2026-09-08", "sources": [ { "title": "Simpler Recycling: workplace recycling in England", "url": "https://www.gov.uk/guidance/simpler-recycling-workplace-recycling-in-england", "read": "2026-09-08" } ] }, { "date": "2027-04-03", "market": "England, Wales, Scotland and Northern Ireland", "nations": "United Kingdom", "state": "earliest possible", "kind": "operation", "title": "Martyn's Law can commence, and an event of 800 or more becomes a qualifying event", "instrument": "Terrorism (Protection of Premises) Act 2025", "binds": "The person responsible for the premises or the event, which at a festival or a show is the organiser rather than the caterer or the welfare supplier", "asks": "Nothing of the unit itself. The Home Office is explicit that the Act does not require physical alterations or the purchase of equipment. What it asks of a unit's operator is to be inside somebody else's procedures, which means knowing whose they are before arriving on the pitch.", "what": "The Act received Royal Assent on 3 April 2025 and the Home Office states the implementation period will be at least 24 months from that date, so this is the earliest it can bind rather than a commencement date. Premises where 200 to 799 individuals including staff may reasonably be expected are standard tier; 800 or more are enhanced tier. An event qualifies at 800 or more, and events beneath that are not in scope. The Security Industry Authority is the regulator and may issue penalties.", "who": "Event organisers, venue operators, and every caterer or welfare supplier standing inside a qualifying event.", "open": "The commencement date is not set. The 24 month figure is the Home Office's own statement of intent, and the date is confirmed when a commencement order is made.", "source_ref": "gov.uk, Home Office overarching factsheet, read 2026-09-08", "sources": [ { "title": "Terrorism (Protection of Premises) Act 2025: overarching factsheet", "url": "https://www.gov.uk/government/publications/terrorism-protection-of-premises-act-2025-factsheets/terrorism-protection-of-premises-act-2025-overarching-factsheet", "read": "2026-09-08" }, { "title": "Terrorism (Protection of Premises) Act 2025 collection", "url": "https://www.gov.uk/government/collections/terrorism-protection-of-premises-act-2025", "read": "2026-09-08" } ] }, { "date": "2027-10-01", "market": "England and Northern Ireland", "nations": "England and Northern Ireland", "state": "in force from", "kind": "operation", "title": "The deposit return scheme starts, and selling a canned drink makes you a retailer under it", "instrument": "The Deposit Scheme for Drinks Containers (England and Northern Ireland) Regulations 2025, SI 2025/67", "binds": "Anybody selling drinks in scope containers to a consumer, which reaches a coffee trailer and a mobile bar", "asks": "A return point unless an exemption is granted, which is a question about space at the serving counter and about where returned containers are held. On a unit with two square metres of counter that is a specification question, and it is one to answer before the unit is built rather than after.", "what": "The regulations come into force on 1 October 2027, with the enforcement provisions relating to the deposit management organisation in force earlier. An in scope retailer must operate a return point unless exempted, and the instrument carries a schedule dealing with exemption applications that are ongoing on 1 October 2027, which is a signal that applications are expected well before it.", "who": "Any operator selling drinks in scope containers in England or Northern Ireland.", "open": "Wales has its own regulations, made in 2026, and Scotland runs a separate scheme. This row is England and Northern Ireland only and the others are not published here until they are read to source.", "source_ref": "legislation.gov.uk, SI 2025/67 regulation 1, read 2026-09-08", "sources": [ { "title": "The Deposit Scheme for Drinks Containers (England and Northern Ireland) Regulations 2025", "url": "https://www.legislation.gov.uk/uksi/2025/67/regulation/1/made", "read": "2026-09-08" } ] }, { "date": "2025-03-31", "market": "England", "nations": "England", "state": "in force", "kind": "operation", "title": "Workplace recycling separation is in force, and it names construction sites", "instrument": "Simpler Recycling in England, workplace recycling", "binds": "Every workplace in England with ten or more full time equivalent employees", "asks": "Containers and a place for them. The guidance requires food waste to be separated always, and names construction sites as having to separate cardboard packaging from new appliances and food or packaging waste from contractors on site, which is what a welfare unit's waste actually is.", "what": "Workplaces in England must separate recyclable waste before collection, including waste produced by employees, customers and visitors, and food waste must always be separated. Construction sites are named: cardboard packaging from new appliances and food or packaging waste from contractors on site must be separated from other construction waste.", "who": "Workplaces in England with ten or more full time equivalent employees, and construction sites.", "open": "", "source_ref": "gov.uk, Simpler Recycling workplace guidance, read 2026-09-08", "sources": [ { "title": "Simpler Recycling: workplace recycling in England", "url": "https://www.gov.uk/guidance/simpler-recycling-workplace-recycling-in-england", "read": "2026-09-08" } ] }, { "date": "2026-01-01", "market": "United Kingdom", "nations": "United Kingdom", "state": "in force", "kind": "operation", "title": "Packaging producer responsibility catches almost no single unit operator, and the thresholds say why", "instrument": "Extended producer responsibility for packaging", "binds": "A business is obligated only if it supplied or imported more than 25 tonnes of packaging in the UK in the previous year and its worldwide annual turnover was £1 million or more", "asks": "Nothing, for almost every operator of a single unit. Both thresholds have to be met, and a corporate group is tested as a group rather than company by company, which is the part a franchise or a fleet has to check.", "what": "Obligation under extended producer responsibility for packaging turns on two thresholds together: more than 25 tonnes of packaging supplied or imported in the UK in the previous year, and worldwide annual turnover of £1 million or more. A holding company tests its corporate group as a whole, and if the group totals meet the large producer criteria then every member is a large producer whether or not it meets them alone.", "who": "Suppliers and importers of packaging or packaged goods, tested at group level where a group exists.", "open": "", "source_ref": "gov.uk, check if you must comply with EPR for packaging, read 2026-09-08", "sources": [ { "title": "Check if you must comply with EPR for packaging", "url": "https://www.gov.uk/guidance/check-if-you-must-comply-with-epr-for-packaging--2", "read": "2026-09-08" } ] } ] }