Insurance Ireland supports all of the recommendations in the report. The core recommendation is that the Minister for Transport should ensure the creation of a one-stop shop online portal for accessing key car history information. The online portal will be a great help for consumers, all the more so when it is enhanced to contain information on economic write-offs, vehicle recalls and mileage in line with other recommendations in the report.

The CCPC decided to prepare this report as every year they are contacted by thousands of consumers who have encountered a problem with a used car they have bought. The focus of the report is on cars and how the State could improve how it collects and shares information in the interests of consumers. The report calls for:

• The Minister for Transport to ensure the creation of an online portal which should be a one-stop shop for accessing key car history information.
• Sharing of information on economic write-off cars and vehicle recalls with consumers through the portal.
• The Department of Transport to consider reporting on crashed cars by automotive professionals such as dealerships and repairers.
• Provision of improved mileage readings through the one-stop shop online portal.
• Ensuring access to information for car history providers for improved services to consumers.

The report notes that, while the State in the form of the Department of Transport and Road Safety Authority collects important information about a car’s history in Ireland, this information is not shared directly with consumers, e.g. mileage readings are recorded during National Car Tests(NCTs) but not shared publicly. There is no system to warn consumers that a used car has been recalled for safety issues. And, while information on end-of-life write-offs is collected by the State, information on economic write-offs is not.

To delve more deeply into the report, an economic write-off is a car that has sustained damage in an incident and been assessed by an insurer on foot of an insurance claim to be capable of repair but the insurer has chosen not to repair the vehicle for financial reasons. An economic write-off is not to be confused with an end-of-life write-off,  which has been assessed by an insurer on foot of an insurance claim to be beyond repair and a danger to the public.

End-of-life vehicles are broken down into Category A and Category B write-offs. A Category A write-off is suitable for scrapping only and has few or no economically viable parts. By contrast, a Category B write-off can be used for spare parts. Meanwhile economic write-offs are subdivided into Category C or Category D write-offs. A Category C write-off is where a car is capable of repair but the repair costs including VAT exceed the pre-accident value of the vehicle. A Category D write-off is a car that is suitable for repair and the repair costs including VAT do not exceed the pre-accident value of the car.

The report discusses whether the UK classification of economic write-offs is better than the current Irish C/D categorisation. The S or N categories in the UK distinguish between economic write-offs on the basis of whether they have sustained damage to any part of the structural frame or chassis( the “S” category) or whether the damage is non-structural( the “N” category). The report notes that the Irish C/D approach primarily focuses on the economic implications of the state of a car whereas the UK S/N methodology focuses on the physical condition of the vehicle. Rather than pronouncing definitively on which methodology is better, the report recommends that the Department of Transport carry out further consultation with stakeholders to identify  workable definitions for economic write-offs. The report goes on to say that the Minister for Transport should develop and amend a code of practice setting out definitions of economic write-offs and criteria for reporting them. The CCPC believes that this approach would be better than an insurance industry voluntary code and it would also be more flexible than including definitions in primary or secondary legislation.

All in all, there is little to argue with in this report, which succeeds in explaining the difficulties faced by consumers in the used car market. The recommendations are sensible and there to protect the consumer, all the more important because, as the report points out, the CCPC has no enforcement role in consumer to consumer( or private to private) used car sales as distinct from sales by used car traders where the CCPC does have a role. The Department of Transport has said it will review the report and consider any matters relevant to it in due course.

This is a complex area with many stakeholders involved but the creation of a one-stop shop portal for accessing key car information would be a gamechanger for consumers. Such access would also help to reduce the number of problems and complaints associated with buying used cars.