You Were Genuinely Loading or Unloading at the Time

Stopping on a yellow line to load or unload is normally allowed, because a single or double yellow line restricts WAITING and loading is not waiting. Two things decide whether it helps you, and the first is on your ticket. Look at the contravention code. Code 01 is "parked in a restricted street during prescribed hours" — a waiting restriction, and loading is permitted. Code 02 is "parked or loading and unloading in a restricted street where waiting AND loading and unloading restrictions are in force" — there, loading is banned too, and it is marked on the ground by short yellow blips on the kerb at right angles to it. If you have a code 02 and there are no kerb blips, that is worth raising in itself. The second thing is evidence that you were genuinely loading: goods actually being moved to or from the vehicle, continuous activity, and you not away from it longer than the load reasonably needed. Delivery notes, timestamped photographs and a witness carry this far better than an assertion. This is a factual defence — that the alleged contravention did not occur — rather than a plea for leniency.

Legal basis

The loading exemption is not a free-standing statutory right; it is a function of what the traffic regulation order restricts. A single or double yellow line is a WAITING restriction made under the Road Traffic Regulation Act 1984 (sections 1 and 2 outside Greater London, section 6 within it) and indicated under the Traffic Signs Regulations and General Directions 2016; loading is not waiting, so it falls outside the prohibition unless the order also restricts loading, which is marked by kerb blips. The distinction is visible on the notice itself: the Secretary of State's statutory guidance for local authorities in England on civil enforcement of parking contraventions lists contravention code 01 as "Parked in a restricted street during prescribed hours" and code 02 as "Parked or loading and unloading in a restricted street where waiting and loading and unloading restrictions are in force". The ground of representation is "the alleged contravention did not occur" — regulation 5(4)(a) of the Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022 (SI 2022/576). WALES: this row is served in Wales as well as England, and the instruments cited above are the England regulations. The Welsh equivalents are the Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (Wales) Regulations 2013 (SI 2013/359) for the grounds of representation and the appeal machinery, and the Civil Enforcement of Road Traffic Contraventions (General Provisions) (Wales) Regulations 2013 (SI 2013/362) for the general provisions. A Welsh notice should be answered on the Welsh instrument; the argument is the same, the citation is not.

How to identify this in your case

You were actively loading or unloading when the ticket was issued. Start with the contravention code on the notice. Code 01 is a waiting restriction, and loading is permitted — this ground applies. Code 02 means the order restricts loading as well, which should be marked by short yellow blips on the kerb at right angles to it; if you have a code 02 and there are no kerb blips, that is worth raising on its own. Then gather what proves the loading was genuine: delivery or collection notes, timestamped photographs, a witness. What loses these cases is not the law but the evidence — an assertion that you were loading, with nothing to show goods actually moved or how long you were away from the vehicle.

Sample appeal wording

Before you send this

Deadline. A late submission can be turned down without your argument being read. Check your notice for the deadline and how it is counted.
Paying may end it. Paying can count as accepting the notice and can close a challenge already under way. Part-paying or acknowledging an old debt can also revive a time limit that had expired.
The amount can change. Check what happens to the sum if you challenge — it may be held, re-offered lower, or keep rising, and fees or enforcement can continue meanwhile.
Use the official route. Use the method, recipient and form your notice specifies, with any reference, evidence and signature it asks for. Sent elsewhere, it may not count.
Only say what is true. Do not copy any statement of fact unless it is true for you, and check the legal point still applies. Delete what does not fit. It may be treated as your statement.
Careful what you volunteer. Avoid unnecessary admissions — naming the driver or accepting responsibility can remove arguments. But answer anything you are legally required to answer, and do include the evidence your ground needs.
Keep the record. Keep what you sent, the attachments, any receipt, and the reply. Note the next deadline.

Sample wording to adapt and send yourself — it may not fit your notice or the stage you are at. Replace the bracketed prompts with your own details; leave any case citation as it is.

Dear Representations Team, Re: PCN [NUMBER] — Vehicle [REG] I challenge this penalty charge notice on the ground that the alleged contravention did not occur, because the vehicle was not waiting — loading and unloading were actively in progress. The notice records contravention code [CODE]. A single or double yellow line restricts waiting, and loading is not waiting; loading is only prohibited where the order also restricts it, which is marked by kerb blips at right angles to the kerb. [Delete as appropriate: There are no loading restriction marks at this location, and I attach photographs. / The notice records code 02, but there are no loading restriction marks at this location, and I ask the authority to produce the traffic regulation order and photographs of the markings it relies on.] Loading was genuinely in progress: 1. Goods being moved: [describe] 2. Between [START TIME] and [END TIME], continuously 3. I was not away from the vehicle for longer than the load reasonably required, because [reason] Evidence enclosed: [delivery or collection notes, timestamped photographs, witness details]. I ask for the notice to be cancelled. That is the ground at regulation 5(4)(a) of the Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022 — the alleged contravention did not occur. Yours faithfully, [NAME]

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Sources

Statutory guidance for local authorities in England on civil enforcement of parking contraventions (DfT) — contravention codes 01 and 02:
https://www.gov.uk/government/publications/civil-enforcement-of-parking-contraventions/guidance-for-local-authorities-on-enforcing-parking-restrictions
Road Traffic Regulation Act 1984 — traffic regulation orders:
https://www.legislation.gov.uk/ukpga/1984/27/contents
SI 2022/576 regulation 5(4)(a) — "the alleged contravention did not occur":
https://www.legislation.gov.uk/uksi/2022/576/regulation/5