New Brake Performance Testing Standards: What They Mean for You
Tuesday 4th March 2025
Successfully maintaining the roadworthiness of Heavy Goods Vehicles (HGVs) and trailers helps to ensure the safety of drivers and other road users while minimising unplanned downtime and the inevitable cost and disruption that goes with it.
Regular brake testing plays a major role in ensuring vehicle safety and the Driver and Vehicle Standards Agency (DVSA) has recently updated their guidance on how these tests should be carried out.
With the new rules set to come into force from April 2025, let’s take a look at what this means for commercial fleet operators.
Braking performance assessments
As things stand, every safety inspection must include a brake performance assessment. This can be via an Electronic Brake Performance Monitoring System (EBPMS) report, a Roller Brake Test (RBT) or a decelerometer.
Since January 2023, it has been a requirement for vehicles and trailers to be appropriately laden for their annual MOT test. Ideally, this should be as close to the vehicle’s Gross Vehicle Weight (GVW) as possible so as to replicate real-world conditions. For the purpose of testing, this equates to a load of 65% or more.
Changes to laden brake tests
As of April 2025, unless an EBPMS is installed, the number of laden roller brake tests required each year will increase from one to four, including the annual MOT, and these tests must be spread evenly across the year.
There are some exceptions to the rules for vehicles where their construction or weight prevents the use of an RBT when loaded. This could be because the load compartment contains extensive racking, the floor is unable to withstand the necessary weight, or a temporary load would risk contaminating food products etc. Other exclusions include:
- Vehicles that run at less than 65% of the permitted axle weights for more than 70% of the time. (this may include car transporters)
- ADR vehicles designed to carry dangerous loads. (if specialist facilities are not available)
- Livestock carriers with no other means of loading.
- Vehicles specifically designed and constructed to carry noxious loads.
- Vehicles designed and constructed as furniture removal vehicles
- ULTAST (Unladen Tri-axle Semi-Trailer) – trailers that run at less than 65% of the permitted axle weights for more than 70% of the time.
- Public Service Vehicles (PSV) including prisoner transfers.
- Vehicles operating at 50% or more of permitted axle weights when unladen, including:
o Fixed plant
o Mobile libraries
o Compactor vehicles
o Exhibition type vehicles
o Bullion vehicle
It’s worth noting that these are just the examples provided by the DVSA; however, it’s not an exhaustive list and so if you think that your vehicle or trailer should be exempt then you will need to be absolutely sure that there is a valid reason for not carrying out the required number of laden roller brake tests.
The reasons for exclusion must be included within a fully documented risk assessment and there should still be at least four unladen roller brake tests per year, unless the construction or weight of the vehicle prohibits the use of RBT equipment.
Whatever the situation, every safety inspection still needs to include a braking performance assessment. In other words, when there is no requirement for a laden brake test to be conducted, braking performance must be assessed using data from an EBPMS, an unladen roller brake test or, if this is not possible, a decelerometer with temperature measurements.
Risk assessments
Unless an EBPMS system is in place and able to provide a detailed report of in-service braking, a detailed risk assessment must be available to support every safety inspection where a laden brake test is not completed.
The risk assessment should be checked at each inspection to ensure it is still relevant and then stored with the vehicle’s other maintenance documentation and retained on file for 15 months. A full reassessment is required every 12 months.
The risk assessment needs to include all factors relevant to the construction and operation of the vehicle, including:
- Vehicle type and age.
- Vehicle manufacturer recommendations.
- Type of load carried.
- Equipment and fittings (either carried or supported).
- Typical operational use, including:
o Type and range of operations
o Terrain and nature of environments
- Distance, speeds, and journey times.
- Details of the previous inspection:
o Brake performance results.
o Brake system and component condition.
- Reasons for not conducting a laden brake assessment.
Electronic Brake Performance Monitoring Systems (EBPMS)
An EBPMS can be a less disruptive means of measuring braking performance, with less downtime that an RBT. In essence, the system collects data from various components, such as wheel speed and brake pressure sensors, to assess how well the brakes are working and then produces one or more reports that detail in-service braking performance.
Another advantage of using an EBPMS is that it can provide real-time feedback, identifying issues such as uneven braking, brake imbalance, or fading, which can then be used to conduct preventative maintenance that helps reduce the risk of unexpected or prolonged downtime.
While an EBPMS is capable of producing all the necessary data and reports needed prior to each safety inspection, this must be analysed and interpreted by someone the DVSA describes as a ‘competent person.’ This is a rather loose term, but it basically means someone with sufficient knowledge, skills, and experience to interpret the data correctly. In evaluating an employee’s capability in this regard, it’s important to remember that the fleet operator (not the employee) is ultimately responsible for the safety and roadworthiness of the vehicle.
Once completed, the evaluation must be signed, dated, and attached to the vehicle record, together with the performance data report. However, there must be sufficient braking events over the period in order to provide accurate data. As a result, an EBPMS may not be appropriate for infrequently used vehicles.
Overall, an EBPMS can be a viable alternative to laden roller brake testing for some fleet operators. That said, they can be costly to install and so it is often a question of whether the cost of the system is higher or lower than the financial impact of any downtime saved. Even with an EBPMS, a laden roller brake test will still need to be conducted as part of the annual MOT.
Decelerometer with temperature readings
Although laden roller brake testing or an EBPMS are the primary means of complying with the new guidance, a decelerometer can still be used in certain circumstances, such as when the type or construction of a vehicle or trailer means it simply cannot be tested with a minimum 65% load on RBT equipment. In short, while the DVSA say that a decelerometer can be used if absolutely necessary, it is very much a last resort.
As the name suggests, decelerometers measure the rate at which a vehicle slows down. During a brake test, the decelerometer is typically attached to the vehicle’s interior or chassis, and it records the deceleration as the brakes are applied. This can be useful for determining the overall efficiency of the braking system, but it’s not so good for isolating specific issues.
A calibrated decelerometer test is only acceptable if accompanied by a series of temperature readings. This reason for this is that without pre- and post-braking temperature measurements, it is impossible to determine whether the braking system is performing to the required standard.
If the brakes are working correctly, they should show a noticeable increase in temperature after the test and the readings should be relatively consistent for each brake across an axle. Any issues identified must be rectified immediately and, if it is not possible to obtain accurate readings, another method must be used.
Is this legislation or guidance?
The legislation itself isn’t changing, but the DVSA’s Guide to Maintaining Roadworthiness is one of the key methods used to assess whether a fleet operator is adequately fulfilling their O Licence obligations. So, although not written into legislation, the guidance provided should be viewed as a requirement for all HGV operators.
If you have any questions about the new guidance and what it means for your business, just get in touch with our commercial vehicle specialists and ask them to tell you about how we’ve helped fleet operators just like you to run a safer, greener, more efficient fleet.