CAM Legal Landscape: Off-Highway

Deploying automated vehicles on private land — in ports, airports and factories — sits outside the regulatory framework governing on-road autonomous vehicles. The Automated Vehicles Act 2024 does not apply. The legal picture is instead shaped by a complex web of contract law, tort, health and safety legislation, product safety regulations, data protection requirements and location-specific byelaws.

This guidance, authored by the regulatory team at Burges Salmon LLP and commissioned by Zenzic, provides organisations planning off-highway CAM deployment with a structured map of every relevant area of law. It is designed to serve both non-legal readers — giving accessible summaries of each legal area and its relevance to CAM — and legal advisers seeking a baseline understanding of applicable law to inform their own advice.

• Port operators & harbour authorities: Operators considering automated port trucks, baggage handling, or cargo logistics. Specific H&S regime (HSE/MCA) and port byelaws apply. Harbourmaster authority and NIS Directive likely in scope
• Airport operators & ground handlers: Operators considering automated airside vehicles, passenger transfer or ground logistics. CAA regulatory framework and Civil Aviation Publications (CAPs) apply alongside HSE. Specific airside byelaws in scope.
• Legal advisers & risk managers: In-house counsel and external legal advisers seeking a baseline understanding of applicable law before providing specialist advice. The document is structured to serve both accessible and detailed legal reading.
• AV technology providers & integrators: Manufacturers, importers, distributors and system integrators of AV components and systems — who bear obligations under product safety law and may have H&S duties under HSWA Section 6.