Are frameless magnetic license plate holders legal or not?

Since March 2023 at the latest, many of our current or future customers have been wondering whether magnetic license plate holders are legal. But how did this happen and how did we at IVALITY react to be legal again? We try to provide information here and provide all the figures, data and facts we know in one article.

What was the legal situation until the beginning of 2023?

Before 2023, the legal situation was quite simple: According to the FZV and STVZO, the license plates simply had to be “firmly attached” to the front and back . Of course, that was worded very vaguely and any official or examiner could interpret the "fixed" as he/she wanted.
Fun fact: Every one of our customers who was given a warning and took legal action against it has been proven right in court because our magnetic holders are form-fitting and firmly attached.

What changed at the beginning of 2023?

At the beginning of 2023, the Federal Motor Transport Authority (KBA) further detailed the wording "fixed" in its announcement 3/2023 and defined further properties that license plate holders must meet in order to be able to receive an ABE.
This is what it says: “Section 10 paragraph 5 of the Vehicle Registration Ordinance (FZV) requires the “fixed attachment” of the license plate to the front and back of the vehicle. In practice, the "permanent attachment" is sometimes interpreted differently. According to a common understanding of the Federal Ministry for Digital and Transport (BMDV) and the highest state authorities responsible for vehicle registration, a license plate attachment meets the requirement of a permanent attachment within the meaning of the FZV if for Removing an attached license plate requires a tool..."²
In other words, “permanently attached” becomes “license plate can only be removed with a tool.”

Fortunately, another sentence was added here:
"A direct attachment of license plates and their possible holder on the vehicle (e.g. using two screws through the license plate or through the holder in the body) is not absolutely necessary for this.... "²
In other words, no special license plate holders are banned. You are free to choose as long as the license plate holder meets the requirements.

And what about license plate holders that can be removed without tools?

The KBA has come up with something here too:
"For license plate fasteners that can also be removed without tools, a general operating license can be applied for from the Federal Motor Transport Authority. The essential requirements for a relevant general operating license for a license plate holder are announced below.... "²

So there are two ways to be legal. Firstly, you have a license plate holder where the license plate can only be removed with a tool or you have a license plate holder with ABE.

And what does a license plate holder have to fulfill if the license plate can be removed without tools in order to get an ABE?

Here too, the KBA defines some properties that a license plate holder must meet in order to be issued with an ABE.
" For all types of fastening (including adhesive, Velcro, magnet or similar fastenings) of the license plate, its "firm attachment" must be ensured. When driving on cobblestones with potholes ("Belgian Block") and when using gantry car washes, car washes or self-service car wash boxes, the license plate must not be lost .
"Fixed attachment" must be ensured for all types of fastening, even in the event of environmental influences such as temperature fluctuations, moisture, impact and shock loads, UV weathering and corrosive media . For a general operating permit, the applicant must provide appropriate evidence.... "²

It all sounds pretty logical, right? I would also want my license plate holder to meet these characteristics!

But what exactly is this announcement and how long is it valid?

A proclamation is not a law, but it is valid, as we learned in a telephone conversation with the KBA.
In other words: The announcement can be seen as an extension of the law (FZV) and is legally valid even if the legal text of the FZV or the STVZO has not changed.

Fun fact: The announcement in this form and thus its effectiveness expires on January 1st, 2024. The KBA will review this announcement ahead of time and adjust it if necessary.

How we managed to be legal again in a very short time despite the announcement!

We have risk management internally at IVALITY. This means that even before announcements/laws are announced, we think about what politicians could come up with to ban magnetic license plate holders. From these scenarios we then derive measures as to how we can still remain legal.

We had plans in hand for these measures and were able to bring an extension onto the market 4 weeks after GTÜ published it in the media (thank you very much for that! It's a shame that an authority didn't do it so well) that made our magnetic license plate holders fully legal again FZV compliant.
This makes us the only provider of legal magnetic license plate holders in the world according to the current FZV!

Would you like to know more about our legal magnetic license plate holders?
Then please click <<<here>>> or write an email to info@ivality.de

Source:
² Verkehrsblatt - Official Gazette of the Federal Ministry for Digital and Transport of the Federal Republic of Germany, Volume 77, 2023 Issue 3 (45-68), Issued in Bonn on February 15, 2023, Verkehrsblatt Verlag, pp.58-59