London NRMM Low Emission Zone

London NRMM Low Emission Zone

Since 2015 there has been a Low Emission Zone for Non-Road Mobile Machinery (NRMM) that covers the whole of Greater London. Currently this non-road emission zone only applies to construction and demolition sites who have needed to apply for planning permission. It also only applies to machines that have a rated engine power between 37kW and 560kW.

Note that some sites and Local Authorities adopt similar emission standards voluntarily, so you may encounter NRMM emission requirements in other regions and industries.

What is NRMM?

Non-Road Mobile Machinery (NRMM) is a broad category that covers the vast majority of diesel machinery on site, even those with road going registration plates, such as telehandlers and dumpers, and machines that are not self-propelled, such as generators and compressors.

Current Emission Requirements

The emission levels from non-road machinery is classified in ‘Stages’, ranging from Stage I/1 (most polluting) through to Stage V/5 (cleanest diesel engines available). 

The NRMM Low Emission Zone covers the whole of Greater London. An interactive map of the zone is available here.

All NRMM with a rated engine power between 37 – 560kW used on construction/demolition sites must meet Stage IV emissions as a minimum. Some types of NRMM are not available at emission Stage IV. As these emission standards are a 'minimum', suppliers should aim for Stage V in those instances. 

Local Authority enforcement officers carry out routine site visits to check compliance with the NRMM Low Emission Zone and there are penalties for non-compliance. The exact penalties vary according to the Local Authority (there are 33 in London), however they are generally legal planning notices (which can lead to a Stop Notice), or fines under a Section 106 agreement.

Future of the requirements

From 1st January 2030 all NRMM within Greater London will need to meet Stage V as a minimum.

The Mayor of London aims for London to be zero emissions from NRMM by 1st January 2040.

NRMM Registration

Sites must register the plant and emission stages of the machines they use/hire on the Mayor of London NRMM Website here: Non-Road Mobile Machinery (NRMM) | London City Hall

This is the responsibility of the Principal Contractor on site, however they will often need information about the machine from the supplier, such as the machine’s EU Emission Type Approval Number.

Machinery with a rated engine power below 56kW

Machinery below 56kW is not available at Stage IV. To comply with the minimum standards sites must therefore use emission Stage V machines at these engine sizes. Remember that machines below 37kW do not need to comply.

Generators

Diesel generators are not available at Stage IV. To comply with the minimum standards sites must therefore use emission Stage V generators.

Stage V generators are often not compatible with long periods of low-loading, which can lead to exhaust blockages and asset damage. The Greater London Authority (GLA) expect sites and suppliers to consider power management technologies such as battery, flybrid, and load on demand, to overcome these challenges.  

Sites can apply for an exemption if they have tried but are unable to source/use a Stage V generator. In those cases sites and suppliers should be prepared to provide detailed justification why use of a Stage V generator is not possible. This will usually include:

• Correspondence evidencing that the site has requested a Stage V generator.
• What the generator is being used for, and any low loading challenges that apply. Loading data if available.
• A statement from the supplier outlining their investment plans for Stage V and other pertinent low emission technologies, dated within the last 6 months.

Retrofit

Machines that do not meet the minimum standards can be retrofitted with exhaust emission abatement technology as an alternative means of complying with the NRMM LEZ. The retrofit product must be endorsed by the Energy Saving Trust NRMM certification scheme, and must reduce emissions to the equivalent of the required compliant emission Stage.

Determining which retrofit product is suitable for your machine can become quite technical. Before purchasing and installing a retrofit, always check with the retrofit supplier what emission Stage the machine’s emission levels will now be equivalent to, and get that confirmed in writing.

The retrofit supplier should provide a certificate of installation following fitment, stating what system has been fitted and what the resultant emission compliance levels are. When the machine is registered on the NRMM Register, this certificate must be uploaded alongside it.

Exemptions

There are currently two types of exemption that can be applied for:

In-house labelling

It is advisable for suppliers to add bespoke labels to an easily accessible/visible part of the machine, containing the EU Emission Stage and Emissions Type Approval Number. 

Statutory engine markings can be difficult to find, and do not clearly state the engine’s emission Stage, it is given as a code. Because of this, sites often struggle to assess machines for compliance and can spend a frustrating amount of time doing so. Clear supplementary labelling often makes life easier for site and fleet managers, and can reduce the number of NRMM compliance queries you receive.

There are some national labelling schemes that you can adopt, for example the CEA ECV labelling (CESAR Emissions Compliance Verification ECV), or you can use your own labelling. Note that the original statutory engine markings must not be removed or obscured.

Frequently Asked Questions

Q) What are the penalties for non-compliance? Will there be a daily charge?

A) The GLA do not have the statutory powers to levy any charges for this, as the rules are made under planning legislation. The principle is that it is a total ban, although sites can apply for exemption for particular machines on a case-by-case basis.

Because the requirements fall under planning legislation, penalties vary depending on the approach taken by each Local Planning Authority. The most common form of penalties are a legal Notice to stop works, land charges, or cost recovery for enforcement activity.  

Q) Are there any types of machinery with a block exemption?

A) No. Although there have been block exemptions in the past for generators and truck-mounted cranes, these no longer apply. All exemptions must be applied for on a case-by-case basis.  

Q) My machine is 'Tier 4' emissions, is this the same thing? 

A) No. 'Tiers' are the US emission standards, they don't apply to the EU/UK. In practice, Tiers and Stages are quite similar in emission levels, hence the confusion, but it's best to ignore the 'Tiers' for UK/London purposes. Manufacturers usually acquire both certifications so that the engine can be sold in both the US and EU.

Machinery that is 'Tier interim 4' or 'i4' often also has Stage IIIB certification (non-compliant). Machinery that is 'Tier 4' often also has 'Stage IV' or 'Stage V' certification (compliant until 2030 and 2040 respectively). However, this is an indicator, not a guarantee, and you should always check the EU Stage of your machine for certainty.

Helpful links:

Mayor of London NRMM Website & Register -  https://www.london.gov.uk/programmes-and-strategies/environment-and-climate-change/pollution-and-air-quality/nrmm

Energy Savings Trust Retrofit Accreditation Scheme technical guidance - https://energysavingtrust.org.uk/service/non-road-mobile-machinery-certification/