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). 

In London there are currently 2 types of zone, Greater London (shown in blue) and Central Activity Zone / Opportunity Area (shown in orange):

All NRMM with a rated engine power between 37 – 560kW used on construction/demolition sites in the blue zones must meet Stage IIIB emissions as a minimum. All NRMM in the orange zones must meet Stage IV emissions as a minimum.

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.

Note that the standards are set to increase very soon. From 1st January 2025 there will no longer be 2 types of zone, NRMM across the whole of Greater London will be required to be Stage IV emissions as a minimum.

 

Future of the requirements

From 1st January 2025 there will no longer be 2 types of zone, all NRMM with a rated engine power between 37 – 560kW used on construction/demolition sites in Greater London must meet Stage IV emissions as a minimum.

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 certain information 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, so this only affects machines with a rated engine power between 37kW – 56kW.

 

Generators

Diesel generators are not available at Stages IIIB or 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.
  • A statement from the supplier outlining their investment plans for Stage V and other low emission technologies, dated within the last 6 months.

 

Exemptions

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

Exemption Category

Description

Exemption Period

Viability

The NRMM plant is not currently manufactured to meet the required EU stage or there is an insufficient quantity of compliant plant in the UK supply chain for the task, however, it meets the next best available EU stage and retrofit is unviable, following robust consideration.

365 calendar days

Short-term

The exemption can be requested in emergency situations for NRMM plant that is on site for a period of no greater than 30 days to account for a range of potential circumstances where equipment is urgently required. 

30 calendar days

 

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.

 

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 (soon to be non-compliant), and 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.

Contact

If you have any questions, comments or concerns that you would like to raise regarding the London NRMM LEZ, please feel free to contact our Decarbonisation & Sustainability Manager.

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