Haulage Permits and Trailer Registration Bill [HL]

Debate between Lord Bassam of Brighton and Baroness Sugg

Committee: 2nd sitting (Hansard): House of Lords
Thursday 22nd March 2018 Grand Committee

[Lord Bassam of Brighton]

The amendment I have in this group is just to tease out when the Secretary of State might bring forward the licensing arrangements. We would like to have some idea of the timetable. I accept that this is a Bill the Government do not want to use and I suspect that the industry would rather they did not either. Most of us would think that it would be better to have the current system than what is on offer here, not least because operators will end up being charged. But I would like some idea of the timetable and how the Secretary of State intends to organise these regulations.

I rather take to Amendment 28 in the name of the noble Baroness, Lady Randerson. It is very valuable for Clauses 1 and 3. Obviously, I support Amendment 22, moved by my noble—and good—friend Lord Tunnicliffe.

[Baroness Sugg]

My Lords, this debate relates to the previous group of amendments, although the Government’s view is slightly different, as I will explain.

As I said, we aim to pass regulations under the Bill as soon as possible to implement both the trailer registration scheme and the permits scheme. However, we cannot be sure that this will be within three months of it passing because, as well as having to reflect a full and proper consultation, as the noble Baroness, Lady Randerson, said, it will have to reflect the agreed future haulage arrangements with the EU. The implementation period may also extend the time by which we may need to make regulations; certainly with regard to the permit registration scheme.

We fully understand the practical implications of not having a permit or trailer registration scheme in place. As I said, we will bring forward regulations in good time to deliver these schemes. I am afraid that I am not able to give the noble Lord, Lord Bassam, a specific timetable at the moment. We do not believe that we should include this specific requirement in the Bill simply because it may not be possible to deliver it.

Moving on to the sunset clause for the delegated powers in Clauses 1 and 3, which is similar to the recommendation from the DPRRC, I understand and indeed agree with the intention of sunset clauses to avoid creating new delegated powers that may be not be used, but we do not believe that to be the case with this Bill. The noble Baroness, Lady Randerson, is right to say that we hope we will never use this Bill for the EU agreement because obviously we hope that we will have continued liberalised and open access to our European neighbours, but we will be using the legislation in Part 1 to regulate for permits for international road haulage by UK hauliers once regulations made under it come into force. This means that it would cover all the permit schemes where UK hauliers are required to carry permits, whether that be unlimited in the European Union or whatever may come from that, if needed; existing and future agreements with non-EU countries; and, indeed, the ECMT permit scheme—which we have not heard about so far today.

If the agreement between the UK and the EU does not require the use of permits, the regulations will not prohibit haulage to EU member states without a permit, but they will for other agreements. We believe that the regulations under Clause 1 should also continue to allow us to regulate the permit requirements of our existing and future international agreements, so the delegated power will not be left unused and a sunset clause would be unsuitable in this case.

I understand the concern about using EU exit legislation for other purposes but I hope that noble Lords do not view this clause as granting new, wide-ranging delegated powers. Clause 1 is a re-enactment of Section 1 of the International Road Haulage Permits Act 1975, which the Bill will repeal. This enables the Government to regulate permit arrangements with other countries, and it is important that our preparations for leaving the EU provide a consistent legal basis for all the permits we administer. The amendment would not only restrict the use of the clause, it would also be a restriction on the existing powers the Government already have under the 1975 Act.

Moving on to Clause 3, again we do not believe that there should be a sunset clause in this specific case for a different reason. It allows for the relaxation of the requirement to carry a permit in exceptional circumstances, and we need to use that to cover existing international agreements. I apologise—that is the same reason as for the first group.

Beyond the first set of regulations made under the Bill, they would need to be updated and amended as our new international agreements change or as permit agreements are made. That deals with the temporary exemption.

On the trailer registration part of the Bill, I re-emphasise that regardless of what agreement is reached with the EU, we would still enact this to align with the Vienna convention. I recognise that the amendment would provide for a sunset clause to be extended, but given how we are seeking to introduce the regulations under the clause, we would inevitably need to seek to extend it indefinitely, so we do not think that it would be beneficial.

Haulage Permits and Trailer Registration Bill [HL]

Debate between Lord Bassam of Brighton and Baroness Sugg

Committee: 1st sitting (Hansard): House of Lords
Tuesday 13th March 2018 Grand Committee

[The Parliamentary Under-Secretary of State, Department for Transport (Baroness Sugg) (Con)]

My Lords, I thank all noble Lords for their contributions. The proposed amendments would enshrine in the Bill an objective in negotiating the EU withdrawal agreement and, should a certain agreement be reached, Clauses 1 to 3 would cease to have an effect.

I will speak first to the amendment in the name of the noble Lord, Lord Bassam, and the noble Baroness, Lady Randerson, which seeks continued recognition of Community licences issued by the UK in the negotiations. As I outlined on Second Reading, the Government’s objective is to maintain the existing liberalised access for UK hauliers. Road haulage is at the heart of the £110 billion of trade that takes place between the UK and the EU every year. We are confident of success in the negotiations, as the continued movement of goods is in the interests of both the UK and the EU.

As noble Lords have pointed out, access is currently secured through participation in the Community licence arrangements. Outside the EU, only EEA members are currently party to the Community licence system. Although continued participation in the Community licence arrangements could be one outcome, the best way to secure mutual recognition and continued access for our hauliers will be through negotiations. I am afraid I must disappoint the noble Lord, Lord Bassam, in saying that we do not feel it would be right, or beneficial to our negotiations, to place any negotiation objectives in the legislation. As my noble friend Lord Attlee said, that would tie our hands.

The Government will take all reasonable steps to see that there are no restrictions on the movement of goods. This can take many forms, including the Community licence, mutual recognition of the operator licence or a permit-based agreement. Many international agreements that are permit-based do not restrict the numbers of permits exchanged; indeed, some of our existing agreements do not require permits at all, including our agreement with Turkey. As I said, our aim is to continue the liberalised access we enjoy today.

[Lord Bassam of Brighton]

Will the Minister pause for a moment? The noble Earl, Lord Attlee, said that Amendment 1 would set the objective in stone. It would not. As the noble Lord, Lord Tunnicliffe, said, it simply says that an objective of our negotiations should be essentially to retain what we currently have. What is wrong with trying to do that? How does it tie the Government’s hands? I cannot see that it ties their hands at all. The amendment simply says that that should be an objective. If it is only an objective, what do the Government feel binds them in any way?

--- Later in debate ---

[Lord Bassam of Brighton]

I am not here to listen to the noble Lord, Lord Pannick, in his absence. I am keen to hear the Minister give her explanation, which is what the Committee needs.

[Baroness Sugg]

I will try my best, although I may not be as clear as the noble Lord, Lord Pannick. As I said, the existing Community arrangement is currently only for EU members and EEA members. When we leave the EU, we will not be either of those. What is suggested is one option, but there may well be an equally satisfactory option, such as an unlimited permit system or, as I said, mutual recognition of operators’ licences. We want to be able to keep those options open and not to be sent down the road of agreeing to the Community licence. There is no reason why a permit that replaces the Community licence could not provide the same level of access as exists currently. That could well be our negotiation objective.

On the amendment in the name of the noble Lord, Lord Berkeley, I take the opportunity to reassure him that of course the Secretary of State will take all reasonable steps to meet the demand for permits from UK hauliers. We regularly meet industry to understand its requirements and priorities, which will be reflected in our detailed negotiations with the European Union. While the amendment would not tie our hands in the negotiation, I hope that what I have said gives the noble Lord confidence that it is not necessary to include this aim in the Bill.

[Baroness Sugg]

I understand the noble Lord’s concern. Later, we will discuss Amendment 8, tabled by the noble Lord, Lord Tunnicliffe, which addresses these issues. There is an explanation and, with the noble Lord’s permission, we will address it then.

The amendments on a sunset clause suggest that, should recognition of Community licences be secured as part of our negotiations, Clauses 1 to 3 should cease to have effect. I understand the intention and I agree that we do not wish to create delegated powers if they are not going to be used at any point in the future in relation to EU exit, but I would like to set out why this Bill has a wider application than just to our road haulage access with the EU. It should also apply to the European Conference of Ministers of Transport multilateral permit scheme and our bilateral agreements with non-EU countries.

While these non-EU agreements have, until now, been dealt with under administrative powers, now that we are introducing this Bill we think that it is important that those agreements are brought in scope, so that there is compliance and consistency in the administration, allocation and enforcement of permits with whatever agreement we reach with the European Union. There would be problems with having different legislation covering similar permit schemes. We are keen to ensure that UK hauliers can use one online system to apply and get permits for the EU as well as non-EU countries, as that would reduce burdens on them.

[Lord Bassam of Brighton]

Do I understand the noble Baroness right? Is she seeking to incorporate the ECMT scheme within the parameters of the Community licence? Is that part of the objective of the negotiations?

[Baroness Sugg]

No, not exactly. If the outcome of the negotiations is a permit-based system, whether unlimited or whatever, yes, we would use this legislation for the allocation of other permits for ECMT and non-EU countries. As I said, that is to simplify the system, have everything in one place under the regulations and allow hauliers to have just one point of access. Beyond the first regulations made under this power, they would need to be updated and amended as our international agreements, whether they be with EU or non-EU countries, change over time. We would need to retain the ability to create regulations under the Bill.

--- Later in debate ---

[Baroness Sugg]

I am afraid that until we know the exact system of the permits, we will not be able to give the noble Lord that assurance. Obviously, we need to avoid there being a false market for these permits. We will look at how permits are allocated and if they are limited in any way, which we hope they will not be, we will certainly consider how to avoid that. Again, the allocation system should make sure that additional permits are not allocated to people who are not using them. It is certainly something we will consider.

I hope I have addressed the need for this legislation, regardless of the agreement reached with the EU. I understand the sentiments of noble Lords in proposing these amendments and welcome the discussion it has enabled. However, as I said, we do not believe that the Community licence system is the only way to proceed and therefore do not think the Bill is an appropriate place to set out that negotiation objective. On that basis, I ask the noble Lord to withdraw his amendment.

[Lord Bassam of Brighton]

My Lords, it is the tradition in Grand Committee to agree to withdraw amendments, and I shall shortly do so. However, I am disappointed with the Minister’s response. I thought I gave her a rather generous invitation to accept Amendment 1.

There is something I find more puzzling still. Over the weekend I extended my reading to take in the international road freight permits policy scoping document. While it does not give us a lot more information, paragraph 1.6 says that the Bill is intended to support the Government’s aim of continuing the liberal access for commercial transport to the EU. It goes on to say that the importance of keeping essential trade flowing is recognised by the EU and is strongly in the mutual interest of both sides, and the industry is therefore confident that a deal will be secured to ensure that essential trade flows will continue without any restriction on access.

I take the argument that this is an opportunity for the Government to look at other ways in which haulage could be permitted, not just in the EU but more widely. I welcome the observation made by the Minister about the way in which they are going to try to simplify the permit scheme and, it seemed to me, bring schemes together to look for a simple way forward in the future. The beauty of the Community licence approach is that it is very simple. Once the primary point has been satisfied and you get the standard international operator’s licence in place, things flow from that. Therefore, I do not think that it is too big an ask to try to have that as an objective in the negotiations.

I will obviously undertake to read what the Minister has said in her reply, but I think it likely that I shall want to bring back this amendment, or one very similar, at Report. I do not think we have heard enough from her to persuade me otherwise, hard though she has tried this afternoon. Our haulage industry requires a bit more certainty and a sense of the Government’s direction of travel, what they have in mind and what their objective is.

If I have one fundamental objection to the Bill, it is that it is only a framework and is entirely skeletal. That much is very clear, not least from the reports that have been prepared by the Constitution Committee and the DPRRC. It is not a very satisfactory Bill, because we will end up having something skeletal as a contingency—that is what this Bill is. If we have to press the button and make it go live—to make it work and make it govern the way in which haulage operates as an industry—the Government will end up having to colour in a lot of the blanks that the Bill leaves, and will have to take rather urgent action to do that at a time when most of us, not least the industry itself, will be worrying about issues relating to Brexit.

I am grateful to the Minister for her response and to the noble Earl, Lord Attlee, for his help in attempting to clarify things for her. I am grateful for the support I have had this afternoon for Amendment 1, across the Committee. I therefore beg leave to withdraw the amendment.

--- Later in debate ---

[Baroness Sugg]

My Lords, I thank the noble Lord, Lord Berkeley, and the noble Baroness, Lady Randerson, for tabling these amendments and allowing a discussion on the important issue of haulage between Northern Ireland and Ireland. I take this opportunity to reiterate that this Bill does not create a permit regime or hard border on the island of Ireland. Clarity about this issue is of great importance, given the Government’s commitment to having no physical infrastructure or related checks and controls. We must preserve north-south co-operation, of which transport is a priority area for the North/South Ministerial Council, established under the Good Friday agreement.

The regulations brought forward under the Bill may prohibit a goods vehicle from undertaking an international journey to a country outside the UK, unless they have a permit, where an international agreement has been concluded requiring permits to be carried. In relation to Ireland, we have included an additional requirement that the Secretary of State must certify that the Government of Ireland have consented to the use of permits on journeys on the island of Ireland before this comes into force. This has been included to recognise and respect the long history of co-operation with regards to transport on the island of Ireland; the Government believe it is an important addition to the Bill.

Clause 1 is drafted to make it explicitly clear that regulations requiring permits for journeys on the island of Ireland will not be introduced without that clear agreement; we have singled it out because of the importance of ensuring that there is no hard border.

[Lord Bassam of Brighton]

Just to clarify, if the agreement reached with either the EU or the Government in Ireland was such that they consented to a permit regime being introduced for haulage through Ireland, does that not envisage a situation where there might be a hard border?

[Baroness Sugg]

The clause as drafted ensures that there has to be a direct agreement between the UK Government and the Government of Ireland before any such scheme is introduced. It aims to avoid exactly that.

[Baroness Sugg]

The permits would need to be recognised by the EU to be used. As I said, this is an extra clause to ensure that we can also have a separate agreement between the Government of Ireland and the Government of the United Kingdom before anything is put in place.

[Lord Bassam of Brighton]

Picking up on my noble friend Lord Berkeley’s point, does that mean that there has already been some negotiation between our Government and the EU on the possibility, or prospect, of a permit scheme having to be put in place? Are the negotiators aware that this contingency legislation has been drafted and do they see it as a practical way forward, with all other considerations put aside?

[Baroness Sugg]

As noble Lords will be aware, there have been many conversations between the EU and the UK on Northern Ireland and the island of Ireland. Obviously, that was addressed in the December agreement. I am afraid that I am unable to tell the noble Lord, Lord Bassam—despite consulting widely, as the noble Lord, Lord Tunnicliffe, said—whether this specific piece of legislation has been discussed with the EU in detail. I will find that out and write to him. The example we have given in Clause 1 is an attempt to provide clarity on how the prohibition of using a goods vehicle without a permit in regulations may be limited, so it does not apply to journeys on the island of Ireland. It is designed to show that there is flexibility to agree something different on the island of Ireland, which is why we believe it is important to include an illustrative example.

Moving on to the amendment in the name of the noble Baroness, Lady Randerson, the Bill allows for a range of outcomes while also meeting our commitments on north/south co-operation as set out in the joint report. We do not think that the amendment as it stands will allow us that same flexibility. As we have not yet agreed the arrangements for haulage for when we leave the EU, we want to keep that flexibility to ensure that any agreement can be implemented. The Bill does not give the UK Government the power to restrict the number of trucks crossing the Irish border; it gives us the power only to implement any new cross-border arrangements that are agreed directly with the Republic of Ireland. As I say, both the UK and Irish Governments have made clear their commitment to avoiding a hard border and preserving cross-border co-operation in any scenario. There is no question of either Government agreeing to such restrictions on cross-border haulage.

On the question asked by the noble Lord, Lord Snape, on permits and what they will show, obviously we are consulting carefully on that, but we expect it to be the name of the company—as opposed to the truck—its validity and its unique number, which is similar to what we have on the Community licence.

[Baroness Sugg]

We expect that the permits would be the same; it is just that the agreement on how the permit system is enacted would be made only if it was subject to a direct and separate agreement between the Government of the UK and the Government of Ireland.

[Lord Bassam of Brighton]

Would a company based in Ireland but travelling through the UK require a permit?

[Baroness Sugg]

If its journey would then go on to the European Union, yes, it would. However, if it was going just to the UK, that would fall under the agreement.

I understand that these amendments are designed to ensure that there are no new restrictions and to get clarity on the issue of the island of Ireland. We are committed to this goal and believe the current drafting of the Bill has that intention; as the noble Lord, Lord Tunnicliffe, highlighted, it has been extensively consulted on. However, I will take noble Lords’ comments on this—

[Lord Bassam of Brighton]

I am sorry about this but on the permits from within Ireland that means a company based in Dublin, for example, would require a UK government permit to travel through the UK to go to the rest of Europe and beyond. Have we consulted with the Irish Government on that issue? It seems an important consultation to undertake. What if they are not happy for us to have a permit scheme which will apply to companies based in Ireland? I do not know how many of those there are; possibly not that many, although I am sure there are a sufficient number to be a burden on their businesses. Have they actively considered that?

--- Later in debate ---

[Lord Bassam of Brighton]

My Lords, the noble Baroness raised some interesting issues, some of which I touched on earlier. When I read the impact assessment, I could see that there was clearly some consideration by the Government about the potential impact on SMEs, as the noble Baroness, Lady Randerson, said. The assessment suggests that some SMEs would struggle. Clearly that worries us: we have a vibrant and viable haulage sector that works well and has served our economy well and we do not want to damage it.

I wonder what full-cost recovery really means and I wonder what extra the permit will be paying for. I saw reference in the impact assessment to a suggestion that inspections would be carried out—ones that perhaps do not currently have to be carried out—to make sure that permits are valid and do the job that they are supposed to do in terms of haulage operators being able to move across the EU 27. In particular, there was a suggestion on the trailer registration scheme that some benefits would accrue through an extra inspection regime. That may well be the case—we will have that argument another day and we have amendments that raise some of those issues—but what does full-cost recovery cover? How much is it likely to cost? What will the impact be on SMEs? What sort of inspection regime will take place? Will it mean an expansion in staff? The Minister suggested that the work will be undertaken by the DVLS, is it?

[Baroness Sugg]

The DVSA.

[Lord Bassam of Brighton]

Acronyms sometimes get the better of me. So, what will it look like? How will it feel? How will it operate? What additional burdens will it place on the businesses affected? Where will the inspections take place? I picked up the point made by the Minister that they will not necessarily be at ports, but ports may be the best place; I do not know. I have seen lorries subject to customs inspections at ports, which works very well for some operations. We need answers to all these questions.

Haulage Permits and Trailer Registration Bill [HL]

Debate between Lord Bassam of Brighton and Baroness Sugg

2nd reading (Hansard): House of Lords
Tuesday 27th February 2018 Lords Chamber

[Baroness Sugg]

My Lords, as always, the experience and knowledge in this Chamber has been extremely insightful, and I thank all noble Lords for their contributions. Many noble Lords have pointed out the importance of the Bill to ensuring that there is no disruption to the haulage industry when we leave the EU, and of course I entirely agree. This is responsible planning to ensure that we are ready to deliver the outcome of the negotiations, whatever that may be. I think we all agree on our aim to retain the existing liberalised access for commercial haulage. I welcome that agreement; it may be one of the few that we have during the progress of the Bill.

I apologise that the Bill was not announced in the Queen’s Speech, as highlighted by the noble Lord, Lord Bassam, and the noble Baroness, Lady Randerson. The gracious Speech outlined that alongside the EU (Withdrawal) Bill there would be complementary legislation and that is what this is, but I apologise that it was not explicitly pointed out then.

Many noble Lords, including the noble Lords, Lord Bassam and Lord Teverson, asked about costs and fees for both haulage permits and trailer registration. As I said in my opening words, the Bill provides powers for the Government to set and charge the administration fee. We are consulting on the details of the fees and charges for haulage permitting later this year. Again, as I said, we are doing this in order to minimise any additional burdens and costs for business. We are fully aware that this is going to be a cost for large and smaller haulage firms. The fees will be in line with the current international permit schemes. The noble Baroness, Lady Randerson, asked for some examples. An ECMT permit for one year currently costs around £133 and a bilateral permit for one journey costs around £8, so that is the kind of ballpark figure that we are looking at. However, the exact nature and costs of the permit scheme will depend on the outcome of the negotiations, so we will be setting that out.

On the question of trailer registration, the Bill again provides the powers to set the fees to cover the administration. Again, we are aiming to minimise those as far as possible in order to reduce any burden or cost to businesses. There will be no ongoing annual fees associated with trailer registration. I think the noble Lord, Lord Teverson, asked about numbers; we expect around 80,000 or so will be registered. Once the trailer is registered, the only further fees would be for any subsequent reissue. The system for that is still in development and the cost is still to be determined. We have been doing quite a lot of exploratory work on this and are confident that the registration fee will be significantly below that of the current vehicle registration fee, which is £55.

On caravans, a subject raised by the noble Baroness, Lady Randerson, the scheme will apply only to commercial trailers over 750 kilogrammes. We are speaking to the caravan society, as the noble Baroness mentioned, to further clarify that.

I raised the issue around horses and whether, if a horse was travelling to race abroad on a commercial basis, that would count. I was reassured that horses in that case would be in an all-in-one vehicle; I do not quite know what to call the vehicles, but they would not be in a trailer horsebox. My colleagues tell me that a horsebox is an all-in-one vehicle, rather than a horse trailer, so they would be covered. However, I am going to go back and clarify that further.

The noble Lord, Lord Bassam, asked about the permit application process and how it will work, and the noble Lord, Lord Berkeley, mentioned HMRC. We are working with an existing organisation, the Driver & Vehicle Standards Agency, on the system to allocate haulage permits. That will be building on existing IT systems to create an online permit application system. Obviously hauliers are already familiar with applying to the DVSA for paperwork related to domestic and international travel, so we hope that they will welcome this. Again, we are committed to trying to minimise any additional requirements, and we are working closely with industry to develop those plans. The aim is absolutely that we will be able to take applications and issue permits in advance of exit day, and we are on track to be able to issue permits in late 2018.

[Lord Bassam of Brighton]

My Lords, are the Government so well advanced in their thinking on the permit scheme that they have scoped out an IT system with one of the providers? Are they in negotiation with companies that do outsourcing on data and so on to try to work out exactly what sort of system they might want to put in place and think about what sort of contract they might want to set?

[Baroness Sugg]

We are working with the existing IT system at DVSA, so there would be no additional contract. I can certainly provide the noble Lord with further details on that.

The noble Lord, Lord Teverson, asked about the implementation period. Obviously, this is being discussed. The Government have been clear that the implementation period will be based on existing rules and regulations. I hope that we will reach agreement on that soon, which should provide some reassurance to industry.

The noble Lord, Lord Bassam, asked about the recognition of driver qualifications. The treatment of drivers’ certificate of professional competence will—again—depend on the outcome of negotiations with the EU, but our objective is absolutely to ensure that following our exit from the EU, CPCs will continue to be recognised.

The noble Lords, Lord Teverson and Lord Berkeley, asked about access for foreign hauliers, including cabotage. These, again, are important issues for negotiations that we are considering carefully for any future arrangement. In any scenario, there is existing domestic legislation to provide appropriate access for foreign hauliers coming to the UK, so the Bill does not address that specifically. However, as the noble Lord, Lord Berkeley, pointed out, it is an important part of the negotiations, and it will obviously be part of the discussions.

The noble Lord, Lord Tunnicliffe, and others mentioned ECMT permits. The permitting system operated by the European Conference of Ministers of Transport is an international agreement entirely separate from the EU and will not be part of our negotiations. The ECMT permits currently allocated to the UK are little used and we have absolutely no intention of allowing them after we leave the EU.

As much as I would love to give the noble Lord, Lord Bassam, a timeline for our transport negotiations, I am unable to do so. We are working closely with industry to understand its requirements and priorities, and have been doing so since the result of the referendum. We represent those views to the Department for Exiting the European Union. That department and the Department for Transport stand ready to move forward with the transport negotiations as soon as they begin.

The noble Lord, Lord Snape, spoke about optimism. I agree with him that we do not want to return to rationing. We are optimistic in these negotiations and am pleased that at least my noble friend Lord Attlee shares that optimism. It is absolutely to the mutual benefit of us and the European Union that we maintain liberal access; 84% of the freight transported between the UK and continental Europe is operated by EU hauliers, and it is in both our interests that we have a successful outcome.

--- Later in debate ---

[Baroness Sugg]

If we can track them down, we will certainly get them in. I thank the noble Lord for that suggestion.

[Lord Bassam of Brighton]

Perhaps I can take the noble Baroness back to an earlier point about trailer registration. I do not know whether she has looked at the department’s impact assessment, but it says that one of the indirect benefits will be improvements for road safety, and trailer registration is part of that. It strikes me that this is an opportunity, if the department wants to look at it that way, to secure some long-term benefits from trailer registration, and the Government might want to focus on it in their post-Brexit evaluation of road safety issues.

[Baroness Sugg]

I thank the noble Lord for that suggestion and will go back and study exactly where the safety requirements fall, and whether there is an opportunity within the Bill to further improve safety. I know that there is quite a lot of work on trailer safety going on in the department at the moment.