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Steamdrivenandy

Two Plates On My Wagon .........

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Would I remove the manufacturers weight plate? No simply because I would rather get on my merry way after a stop. Rather than winning my case in court after having my caravan impounded and ruining my trip.

 

This is probably the most important point of all, carrying on with enjoying life using the caravan as an aid to that enjoyment!

The aggravation and inconvenience of proving a point simply is not worth it.

 

The cost of a plate upgrade is truly trivial by comparison.

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In the case of my caravan, the weight shown on the BPW plate is the same as the one on the Dethleff's plate. However, this need not necessarily be the case. My caravan has the maximum factory fitted upgrade of 200kg, bringing it from 1600kg to 1800kg. I don't know whether the same model without the upgrade also has the same chassis, in which case there would be a difference between the weights on the two plates, but somehow I suspect that without the upgrade the chassis would be a different one.

 

Of course on the Continent manufacturer's offer vans with much larger upgrade possibilities but, as Lutz hints, they involve a heavier weight axle being fitted to the chassids during production. The upgrades offered by UK manufacturers are generally paper exercises to bring the MTPLM up to the maximum the standard axle will take. Generally up to the next highest 100kg point. So Lutz's upgrade is probably with a heavier axle that will support 200kg more and for this debate is not relevant.

 

So what we need is a post '13MY Continental van with a standard MTPLM that isn't a 100kg multiple, to see what the Type Approval plate says. I specify 'isn't a 100kg multiple' because the only two Continental built vans I've owned had 1200kg MTPLM's and 1200kg axles.

 

This has triggered the thought that maybe Continental manufacturer's aren't so niggardly with their MTPLM's and actually always sell standard vans at the same MTPLM as their axles. That would totally avoid the issue that we're debating but would upset those that seem to think lower MTPLM's are worth having in order to make van's available to a wider range of towcars.

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This is probably the most important point of all, carrying on with enjoying life using the caravan as an aid to that enjoyment!

The aggravation and inconvenience of proving a point simply is not worth it.

 

The cost of a plate upgrade is truly trivial by comparison.

But if push came to shove I would argue it and expect to win!

It's potential insurance implication that worries me more. For example if my 22 year old Daughter decides she wants a caravan. She does her research and selects a combination with an overall weight of 3490kg based on the manufacturers weight plate. She picks said caravan up from dealer and on the way home she has an accident, let's assume it's her fault, and writes the tow car and caravan off. So she puts in a claim. The insurers look at the type approval and realise that the total weight is not 3490kg but 3510kg and reject the claim on the basis that she is not licensed to drive such a combination what happens then?

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Actually, Axle 0 is the jockey wheel, not the hitch, but that's only a technicality.

 

That the sum of the axle loads is not the MTPLM, but a value greater than that, is not unusual and quite often the case for cars, too.

 

It would seem to me that if the door plate doesn't agree with the bulkhead plate, but shows a lower limit, then it would be perfectly OK to remove the door plate as it doesn't have any legal significance anyway.

No, axle 1 is the hitch, it's one of those known facts.

 

The door plate does have significance in the UK as that's what is used as explained in the O/P for prosecution purposes. I've also given an example of how UK law is diferent from EU. Another example would be motorhomes towing car's. A frames allowed in the UK but not in Germany I believe.

 

Personally speaking I can see that as I posted regarding "down plating" that the caravan manufacturers are following a similar route.

 

I would view the manufacturers plate as a declaration of conformity by them which the NCC standardise and the authorities use as legal precedent as again explained in the O/P.

 

Another example in a loose way of quirks of UK law would be the CMC granting licence to CL's

 

As for giving your guidance to remove the door plate, it's clear you havnt understood or read the O/P as it states prosecution can occur if one isn't displayed and or kept upto date.

 

Also another forum myth is that axles increase in 100kg increments, my Alko axle is plated at the axle as 1550kg,So that suggests not

Edited by Simple Life

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But if push came to shove I would argue it and expect to win!

It's potential insurance implication that worries me more. For example if my 22 year old Daughter decides she wants a caravan. She does her research and selects a combination with an overall weight of 3490kg based on the manufacturers weight plate. She picks said caravan up from dealer and on the way home she has an accident, let's assume it's her fault, and writes the tow car and caravan off. So she puts in a claim. The insurers look at the type approval and realise that the total weight is not 3490kg but 3510kg and reject the claim on the basis that she is not licensed to drive such a combination what happens then?

Nothing.

 

Because in the UK we go on the manufacturers plate.

 

My caravans in storage but I don't think the locker/bulkhead plate shows mtplm. I could be wrong on that, will check up at the weekend when I take the bedding back.

Edited by Simple Life

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No, axle 1 is the hitch, it's one of those known facts.

Are you sure?

 

The door plate does have significance in the UK as that's what is used as explained in the O/P for prosecution purposes. I've also given an example of how UK law is diferent from EU. Another example would be motorhomes towing car's. A frames allowed in the UK but not in Germany I believe.

A frames are tolerated in the UK because there has been no test case to resolve the issue. There is no legislation that confirms their legality.

 

Personally speaking I can see that as I posted regarding "down plating" that the caravan manufacturers are following a similar route.

 

I would view the manufacturers plate as a declaration of conformity by them which the NCC standardise and the authorities use as legal precedent as again explained in the O/P.

 

Another example in a loose way of quirks of UK law would be the CMC granting licence to CL's

 

As for giving your guidance to remove the door plate, it's clear you havnt understood or read the O/P as it states prosecution can occur if one isn't displayed and or kept upto date.

If there is no law that requires a door plate, it surely can't be illegal to remove it. However trying that on modern vans would leave a 'void' mark and any enforcement officer would start asking questions.

Also another forum myth is that axles increase in 100kg increments, my Alko axle is plated at the axle as 1550kg,So that suggests not

A few do have axles in 50kg increments but my post was too long already and I didn't want to split even more hairs

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Of course on the Continent manufacturer's offer vans with much larger upgrade possibilities but, as Lutz hints, they involve a heavier weight axle being fitted to the chassids during production. The upgrades offered by UK manufacturers are generally paper exercises to bring the MTPLM up to the maximum the standard axle will take. Generally up to the next highest 100kg point. So Lutz's upgrade is probably with a heavier axle that will support 200kg more and for this debate is not relevant.

 

So what we need is a post '13MY Continental van with a standard MTPLM that isn't a 100kg multiple, to see what the Type Approval plate says. I specify 'isn't a 100kg multiple' because the only two Continental built vans I've owned had 1200kg MTPLM's and 1200kg axles.

 

This has triggered the thought that maybe Continental manufacturer's aren't so niggardly with their MTPLM's and actually always sell standard vans at the same MTPLM as their axles. That would totally avoid the issue that we're debating but would upset those that seem to think lower MTPLM's are worth having in order to make van's available to a wider range of towcars.

 

I don't know of any Continental manufacturer that doesn't offer their caravans with an MTPLM in increments of 100kg (at least on the Continental market), regardless of how the axle is rated.

 

No, axle 1 is the hitch, it's one of those known facts.

 

The door plate does have significance in the UK as that's what is used as explained in the O/P for prosecution purposes. I've also given an example of how UK law is diferent from EU. Another example would be motorhomes towing car's. A frames allowed in the UK but not in Germany I believe.

 

Personally speaking I can see that as I posted regarding "down plating" that the caravan manufacturers are following a similar route.

 

I would view the manufacturers plate as a declaration of conformity by them which the NCC standardise and the authorities use as legal precedent as again explained in the O/P.

 

Another example in a loose way of quirks of UK law would be the CMC granting licence to CL's

 

As for giving your guidance to remove the door plate, it's clear you havnt understood or read the O/P as it states prosecution can occur if one isn't displayed and or kept upto date.

 

Also another forum myth is that axles increase in 100kg increments, my Alko axle is plated at the axle as 1550kg,So that suggests not

 

In my various responses I have tried to reference the source of my information. I would be grateful if could do the same and quote a documented reference which states that a door plate is a UK legal requirement, because I can't find any such. If it isn't, there should be no reason why it cannot be removed.

 

Please also let us know where it is stated that the hitch is Axle 0 and not the jockey wheel.

Edited by Lutz

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Absolutely certain regarding the hitch as axle 1.

 

Are you sure it's the jockey wheel??? Show us, as you say the reference to such.

 

Regarding A frames if your arguement relies on test cases then this whole thread is futile, as the O/P states a prosecution occurred for a manufacturers plated MTPLM offence when also within the chassis plate weights!

 

Which in your stance shows how important the manufacturers plate is!

Edited by Simple Life

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Absolutely certain regarding the hitch as axle 1.

 

Are you sure it's the jockey wheel???

 

Regarding A frames if your arguement relies on test cases then this whole thread is futile, as the O/P states a prosecution occurred for a manufacturers plated MTPLM offence when also within the chassis plate weights!

 

Which in your stance shows how important the manufacturers plate is!

 

The hitch is also plated to a max. noseweight, but that is a separate issue. The hitch could be plated to 150kg, but the caravan manufacturer could limit it to 100kg, for example.

 

I was not referrring to the chassis plate but to the statutory plate which could also have different values than the door plate (for reasons best known to the caravan manufacturer himself). The statutory plate has the only definitive MTPLM value for the finished caravan. If someone was prosecuted for exceeding the values on the door plate but was still within those on the statutory plate then that could only be because nobody could be bothered to check and compare the two.

Edited by Lutz

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The hitch is also plated to a max. noseweight, but that is a separate issue. The hitch could be plated to 150kg, but the caravan manufacturer could limit it to 100kg, for example.

 

I was not referrring to the chassis plate but to the statutory plate which could also have different values than the door plate (for reasons best known to the caravan manufacturer himself). The statutory plate has the only definitive MTPLM value for the finished caravan.

Your now confusing yourself.

 

The chassis plate is the satutory plate as you call it. The one on the bulkhead.

 

 

I call it the chassis plate as that is what it is, it shows the load capabilities of just the chassis.

 

The manufacturers plate shows for want of better words the load capabilities for the Whole caravan as explained in the O/p.

 

It is only when the manufacturer declares their plate via the NCC and their regulations, can match the chassis plate does the user get the benefits of the increased weight allowance.

 

Now that's a UK system of compliance which their maybe no direct legislation you can google but it's what's used as accepted practice in UK law as is the CC example I gave regarding cl's and I would suggest making it a legally binding practice.

 

I think it's a debate that swings wide of the point.

 

It's not much diferent to trucks, the axles are made by a third party and are plated with higher weights than required, the truck manufacturer down plates the whole vehicle to fit into the particular sector they sell into.

Edited by Simple Life

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Your now confusing yourself.

The chassis plate is the satutory plate as you call it. The one on the bulkhead.

I call it the chassis plate as that is what it is, it shows the load capabilities of just the chassis.

The manufacturers plate shows for want of better words the load capabilities for the Whole caravan as explained in the O/p.

It is only when the manufacturer declares their plate via the NCC and their regulations can match the chassis plate does the user get the benefits of the increased weight allowance.

Now that's a UK system of compliance which their maybe no direct legislation you can google but it's what's used as accepted practice in UK law as is the CC example I gave regarding cl's and I would suggest making it a legally binding practice.

I think it's a debate that swings wide of the point.

It's not much diferent to trucks, the axles are made by a third party and are plated with higher weights than required, the truck manufacturer down plates the whole vehicle to fit into the particular sector they sell into.

No the law is the law. The CC or CMC is it has the right to regulate under the caravan sites and development act 1960 it has applied for and been granted an exemption certificate, as for example have the Girl Guides. Perhaps you can show me what under what act the NCC has been granted powers to stipulate a mamimum legally enforceable weight that is different from the type approval? If it has been used in the past the likely because simply no one has challenged the fact.

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Too late. . posted at the same time

Edited by Simple Life

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For the purpose of documenting the finished caravan the chassis plate is not the statutory plate that counts. The one (usually in the bulkhead) that the caravan manufacturer applies is. Among other things it shows the type approval number for the finished caravan, the name of the manufacturer and the various weights. That type approval is a legal requirement.

 

The chassis plate giving details of the load carrying capacity of the chssis itself is also a statutory plate, but it is referred to as a Stage 1 statutory plate and really has relevance only to the caravan manufacturer (Stage 2).

 

What goes on the door should be no more than a repeat of the Stage 2 plate on the bulkhead, but from what we read in this thread it obviously isn't always.

 

As far as I know there is no requirement that the caravan MUST go through the NCC process.

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Correct me if I'm wrong but for the purposes of the type approval a caravan is just a trailer as would be a horse box or a car transporter.

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No the law is the law. The CC or CMC is it has the right to regulate under the caravan sites and development act 1960 it has applied for and been granted an exemption certificate, as for example have the Girl Guides. Perhaps you can show me what under what act the NCC has been granted powers to stipulate a mamimum legally enforceable weight that is different from the type approval? If it has been used in the past the likely because simply no one has challenged the fact.

The CC is class as an Overseeing Body, and given powers of self regulation I agree.

 

The NCC will be classed as the same. Just because google cannot give you the answer doesn't make the facts as stated in the O/P wrong.

Correct me if I'm wrong but for the purposes of the type approval a caravan is just a trailer as would be a horse box or a car transporter.

Almost correct, their is a section for just caravans, all be it a small section

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The NCC will be classed as the same. Just because google cannot give you the answer doesn't make the facts as stated in the O/P wrong.

 

 

That doesn't make the NCC infallible, though, and and stated, there is no requirement to involve the NCC before a caravan can be legally sold in the UK.

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When I said wide of the point, I agree with the NCC system but rather than up plate I think caravans should be manufactured plated at the maximum, then the user applies to down plate to their requirements.

 

It's what happens in the commercial world and would end confusion in the caravaning world too.

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When I said wide of the point, I agree with the NCC system but rather than up plate I think caravans should be manufactured plated at the maximum, then the user applies to down plate to their requirements.

 

It's what happens in the commercial world and would end confusion in the caravaning world too.

 

Any change in the MTPLM, whether up or down, will always require a new statutory plate and that can only be issued by the manufacturer because he has to confirm that the revised MTPLM is covered by his type approval documentation.

Edited by Lutz

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That doesn't make the NCC infallible, though, and and stated, there is no requirement to involve the NCC before a caravan can be legally sold in the UK.

By definition that Manufacturers plates have been added, and once again referring back to the O/P enforced, it's clear that it does.

 

As I said earlier just because google can't give you the answer doesn't make it wrong.

 

I have given examples of diferences within UK law which are binding. This being another.

 

Any change in the MTPLM, whether up or down, will always require a new statutory plate and that can only be issued by the manufacturer.

Exactly. Don't disagree. Done it myself and I received a new NCC registration certificate too.

 

It's in my hand right now.

Edited by Simple Life

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The CC is class as an Overseeing Body, and given powers of self regulation I agree.

The NCC will be classed as the same. Just because google cannot give you the answer doesn't make the facts as stated in the O/P wrong

This is getting a bit silly. But the CC has been granted certain rights under a specific act of parliament as have other organisations. The list of exempted organisations is freely available. I know of no law that the NCC grants any powers to regulate, it is a trade body its job is to represent and promote its members. If you can come up with any facts to refute this please do.

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This is getting a bit silly. But the CC has been granted certain rights under a specific act of parliament as have other organisations. The list of exempted organisations is freely available. I know of no law that the NCC grants any powers to regulate, it is a trade body its job is to represent and promote its members. If you can come up with any facts to refute this please do.

Again just because google can't give you answers doesn't make it wrong.

 

The facts are on page 1 of this thread.

Edited by Simple Life

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To the best of my knowledge soime Continental caravans are sold in the UK without NCC approval.

Edited by Lutz

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On the front of the NCC Certificate of Compliance.

 

Touring Caravan.

 

BS EN 1645. 1:, BS EN1648. 1:, BSEN721:, BS7671:

 

This is to certify that an example of the touring caravan described on page 2 of this certificate has been approved as a model complying with the applicable clauses of the above standards according to the certification scheme operated by NCC Ltd.

. ....

So as I said, an overseeing body of compliance which has acceptance in UK law as authorative.

To the best of my knowledge soime Continental caravans are sold in the UK without NCC approval.

I wouldn't know. It's certain that their are plenty sold here. It's an interesting point within this thread as to what regulation the UK authorities rely on to allow them on UK roads. Maybe one for Brexit ☺

 

. .

Within the certificate their are EN regulations listed of compliance as well as a manufacturers certificate of compliance and my vin number

Edited by Simple Life

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On the front of the NCC Certificate of Compliance.

 

Touring Caravan.

 

BS EN 1645. 1:, BS EN1648. 1:, BSEN721:, BS7671:

 

This is to certify that an example of the touring caravan described on page 2 of this certificate has been approved as a model complying with the applicable clauses of the above standards according to the certification scheme operated by NCC Ltd.

. .. . .

So as I said, an overseeing body of compliance which has acceptance in UK law as authorative.

 

The BS numbers referred to above are only industry standards according which the vehicle was tested. They have nothing directly to do with whole vehicle type approval other than these standards were used to test compliance in order to gain type approval, but they do not document compliance itself. The only definitive documentation is the Certificate of Conformity issued by the manufacturer, not the NCC.

Edited by Lutz

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If you refer back to the original post the exterior plate is commonly used by enforcement agencies. because it is accessible and was the only source of data up until the EU Type Approval requirement of 2013. I doubt that many of them, even four years later, are aware of the existence of a Type Approval plate.

 

The vast majority of checks where a van is over it's exterior labelled MTPLM are dealt with without any charges being preferred and an amenable way to reduce weight is found and acted upon.

 

If someone does want to make a fuss and point to the Type Approval plate then I suspect the matter would be referred to the CPS to decide whether to prosecute. If they have their wits about them and the rig in question wasn't loaded over the Type Approval plate figure I very much doubt a prosecution would go ahead.

 

This is probably why there are virtually no prosecutions for caravan overloading in the UK. In a sense the lower exterior MTPLM usually provides a 'buffer' where if someone overloads they are still within the Type Approval plate figure.

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