How to Challenge a Code 18 PCN: Offering Goods for Sale

What a Code 18 PCN Alleges

A Code 18 PCN alleges that a vehicle was being used to expose or offer goods for sale in a parking place contrary to its conditions. The central question is what was actually being offered and how the vehicle was being used. A delivery vehicle, a trader visiting a customer and a vehicle being used as a sales stall are not the same situation.

On-Street Parking: PCN, Notice to Owner and Formal Representations

A parking PCN served at the vehicle can be challenged before a Notice to Owner arrives. The later notice is a separate statutory step, not merely another copy of the original ticket. Identify the document you have and send the challenge at that stage.

• PCN on the windscreen or handed to the driver: send an informal challenge to the issuing authority. Explain the disputed parking condition and attach the evidence that supports cancellation.
• Notice to Owner: if one is served, the owner makes formal representations against it. Repeat the relevant evidence and address any earlier rejection; an informal challenge does not replace this response.
• Postal parking PCN: make formal representations against the postal PCN without waiting for a Notice to Owner. The authority needs a lawful basis for postal service, such as qualifying prevented service, a drive-away after the officer began preparing the PCN, or an eligible approved-device case.
• Notice of Rejection: appeal to the tribunal named in that notice. London civil parking cases go to London Tribunals; relevant English and Welsh cases outside London go to the Traffic Penalty Tribunal.

England's camera powers for on-road parking are restricted; the presence of a camera does not authorise postal enforcement of every paid bay. The traffic order and signs govern the restriction, while the notice's legislation governs the procedure. Wales has separate regulations, and local-Act restrictions need their own check.

Parking Challenge Deadlines and the Council's Reply

A PCN served on the vehicle or driver normally allows 14 days at the discounted amount. Challenge promptly and check the council's policy on re-offering the discount. Do not assume that asking for photographs or reporting a machine fault pauses the PCN.

• A Notice to Owner normally gives 28 days beginning with service for formal representations. Use its reference and instructions even if the first challenge has already been sent.
• An English postal parking PCN normally gives 28 days beginning with service for formal representations. The discount is normally 21 days for an approved-device notice and 14 days for qualifying prevented-service or drive-away notices.
• For qualifying formal parking representations in England, the authority must serve its decision within 56 days of receipt. This statutory requirement does not turn every unanswered informal email into an accepted appeal.
• A formal Notice of Rejection normally gives 28 days beginning with service to appeal to the tribunal. Keep the rejection and submission confirmations so the dates can be established.

London Councils publishes borough parking penalties of £160 higher level and £110 lower level in Band A, and £140 and £90 in Band B. The applicable code, location and date determine the amount. TfL and authorities outside London have their own applicable charges; these borough amounts are not national rates.

Show What the Vehicle Was Actually Being Used For

• The officer's photographs of any stall, advertisement, goods or customer transaction.
• A prior order, delivery note or appointment record explaining the commercial visit.
• The trading licence or location-specific permission and its conditions.
• The parking-place order provision relied on, together with photographs identifying the space.

Paying for parking answers a parking-payment requirement, not necessarily a prohibition on sales. Conversely, a company name on a van does not by itself explain how goods were being offered from that parking place.

Was the Vehicle Being Used to Sell Goods From the Parking Place?

• The vehicle was delivering previously ordered goods rather than offering goods for sale from the space. Explain the order, destination and handover, with documents that distinguish the activity from roadside trading.
• The vehicle was simply parked while its user worked elsewhere. Ask the council to identify the sales activity it recorded rather than relying only on business branding or the presence of goods inside.
• The applicable parking order did not prohibit the activity alleged, or the PCN identifies the wrong place or period. Request the provision relied on and compare its wording with the officer's account.
• A street-trading licence or other written permission expressly covered this location and activity. Check whether separate parking permission was also required; a general trading licence does not necessarily override parking-place conditions.

Permission must cover the actual use of the vehicle and parking place. Normal parking payment or a resident permit does not automatically authorise trading. Where the council alleges that the vehicle itself was offered for sale, inspect the order and evidence of that particular allegation rather than assuming every sales advertisement is governed identically.

What to Include in a Code 18 Challenge

Describe the activity first: delivery, parking during a visit, or authorised trading. Answer the particular evidence of sales identified by the officer and attach the relevant order or permission. Avoid treating all business use as either prohibited or exempt.

Where to Send the Parking Challenge

Use the issuing authority's online PCN service or the postal address on the current notice. Include the PCN number, registration, street and a concise explanation connecting each ground to its evidence. Save the completed submission, attachments and acknowledgement.

For formal representations, select the applicable ground and explain it in your own factual account. A sale, qualifying hire agreement or vehicle taken without consent needs the relevant supporting records. Naming a different driver alone does not transfer ordinary council-PCN liability away from the owner.

After Rejection: Formal Representations and the Tribunal

An informal rejection leaves the option of formal representations if a Notice to Owner is served. A formal Notice of Rejection enables an independent tribunal appeal. Focus on the issue the council has not answered, whether that is a valid payment, a permitted activity, an unclear restriction or a procedural error.

If the adjudicator allows the appeal, the penalty is cancelled. If refused, follow the decision's payment instructions. Missing the payment or appeal deadline can lead to a 50% increase at Charge Certificate stage and later an Order for Recovery. These later notices have specific procedural remedies and should not be treated as another ordinary opportunity to dispute the parking event.