Consultation Papers

Below is a full list of recent consultations that the RMI have submitted responses to. Alternatively, you can click on the links below to search for consultation responses relevant to a specific policy area, or search by date using the navigation to the right of the screen.

PRA RESPONSE TO: CHECK, CHALLENGE, APPEAL: REFORMING BUSINESS RATES APPEALS

The business rates appeals system is being reformed. The aim of the reforms, as stated by Government are 'to provide a quicker, clearer and more transparent service to businesses'.

This consultation paper sets out proposals for a 3-stage approach: ‘check, challenge, appeal’, and seeks views from businesses and other interested parties.

The PRA has raised concers with the levels of evidence that must be provided by ratepayers throughout the appeal process and the potential fee requirements. The PRA is concerned that the reforms may be block smaller businesses from accessing the appeal system. 

MOTORING SERVICES STRATEGY: CONSULTATION

This consultation is about setting the strategic direction that the Department for Transport's (DfT) agencies should take over the lifetime of this Parliament. It will inform the strategy which the department intends to publish in the spring of 2016.

The DfT is seeking views on a whole range of agencies' activites. The NFDA and NMDA have submitted a joint consultation response which highlights the need for privatisation of HGV MOT testing, as well as a move to streamline motorcycle testing. 

LAW COMMISSION REVIEW OF BILLS OF SALE

The Law Commission has published a review and proposed amendments to Bills of Sale. This will be followed by a final report (without draft legislation) in summer 2016. Bills of sales are a way in which individuals can use goods they already own as security for a loan. Their use has dramatically grown in recent years, which has been reflected in the increase in the use of logbook loans. 

The RMI, with notable comments its associations the; NFDA, IGA, NAMA and NMDA, has responded to the consultation, endorsing the overall comments and suggestions put forward by the Law Commission. The RMI agrees with the Law Commissions comments that the law on bills of sale is seriously outdated, and causes problems for borrowers, purchasers and lenders alike. This is notably significant and sometimes problematic for the automotive industry as a logbook loan will follow a vehicle, not always transparently. 

APPRENTICESHIPS LEVY: EMPLOYER OWNED APPRENTICESHIPS TRAINING

The Department for Business, Innovation and Skills (BIS) consulted on the proposal to implement an apprenticeships levy on large employers. The levy will enable employers to choose and pay for apprenticeship training. 

The consultation invites comments on:

  • how to pay the levy
  • how the levy should work for employers who operate across the whole of the UK
  • how to make sure that employers paying the levy have the opportunity to get more out than they put in
  • how to best to give employers control of apprenticeships 

More detail on the levy rate and scope will be provided later in the year. 

The RMI's IGA, NFDA, NAB and NMDA all directly contributed to the RMI's over position and response. 

For a summary of the Government's consultation response, click here.

PRA RESPONSE TO: DRAFT REGULATIONS ON THE SALE AND MANUFACTURE OF TOBACCO PRODUCTS

This consultation seeks views on draft regulations on implementing the revised EU Tobacco Products Directive (2014/40/EU).

The revised EU Tobacco Products Directive (2014/40/EU) will replace existing legislation on regulating the sale and manufacture of tobacco products and for the first time regulate e-cigarettes and herbal products. It will apply from 20 May 2016.

The UK has some flexibility in how it might choose to implement the new rules. The purpose of this consultation is to seek further information on the impact of the Directive and flexibilities to inform the government’s final decisions on implementation.

The PRA has placed emphasis on the importance of transposition periods and ensuring that any adverse effects on business are minimal in regards to sales and revenue. 

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