|Don't panic Mister Mainwearing!!!!!!!!!
I am afraid that that this is alarmist nonsense from ACE written by someone who does not know how the EU works. This is simply the first draft of a proposed directive, issued for comment. The DfT have circulated a paper picking out some of the items and requested the reactions of a few organisations. They are not set up at this stage to receive individual comments, and flooding them with individual comments will not be in the least helpful.
What the Commission have done is more or less take the German model of testing, where one of the criteria is whether the vehicle conforms to the original type approval, and what FBHVC will be doing is urging that the UK model is maintained, under which the vehicle as presented is tested for safety related items. The proposal as drafted is wholly impracticable in any event, requiring detailed specifications of every vehicle ever built to be available to the tester, in order to determine whether it has been modified, because a modified vehicle could not be a historic vehicle and therefore exempt, whatever its age.
Has anyone ever heard of ACE before? It seems to me that they may be trying to get themselves known by creating a panic about "Armageddon". That is rather what a certain classic car publication is famous for, scare headlines to attract buyers.