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Mr Plodd

Caravan gross weight, a response from Bailey!

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I appreciate that this is a perennial subject  that keeps cropping up. I emailed Bailey asking about the possibility of upgrading a new Phoenix. I asked what exactly I would get and which of the two stickers (gas locker or external) carries the LEGALLY enforceable MTPLM.  Their response is below.

 


Thank you for your email.  

You can purchase a max upgrade kit which will allow you to increase the MTPLM from 1382kg to 1450kg. A new weight plate is included in the pack and this will replace the weight plate located by the habitation door. Only the weight plate on the outside of the caravan needs to be replaced. In the max upgrade kit, I believe you will receive a new weight plate ( for the outside of the caravan ) a new certificate and two decals. But please confirm this with Prima Leisure https://www. primaleisure. com/

Kind Regards
Jo Barrington
Customer Services Co-ordinator

 

Now, reading the above the cynical part of my brain is asking the question. If there are TWO weight stickers,  and only the one on the outside, which doesn’t carry the caravans VIN number or list the axle weights, “needs to be replaced” what is shown on the plate inside the gas locker?  As I understand it the gas locker sticker shows VIN number, type approval number, and, most importantly, the various axle weights.

 

So it APPEARS that this “Max  Upgrade” is a bit of “smoke and mirrors” job because the gas locker sticker ALREADY shows the LEGALLY ENFORCEABLE MTPLM  

 

I will be responding to Bailey’s response but first I will be going to my local Bailey dealers and checking (and photographing) BOTH plates on a new Bailey. If indeed, as I now suspect, the external sticker carries no legal weight and the guy from VOSA would only use the information on the gas locker sticker a whole can of worms could be opened.

 

Just suppose I have a car who’s train weight is 3499kg with the 1385kg  MTPLM Phoenix who’s OUTSIDE sticker shows an MTPLM of 1382kg.  I am, at that point, legal, BUT if the VOSA man knows about the gas locker sticker and goes by THAT figure I could, in theory, have a gross train weight in excess (by 68kg) of 3500kg and THAT could possibly mean I don’t have the correct driving licence even though it’s the same caravan! 

 

I will I’ll update this thread as and when I have further information.

 

If anyone has a Phoenix perhaps they could post (or pm me) a picture of both plates so I have a bit more information to hand.

 

Could prove interesting !!!

 

Andy

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Perhaps the question should be asked of "the guy from Vosa" not of Bailey. After all, Bailey is a manufacturer, not a legal authority.

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1 hour ago, Mr Plodd said:

 

Just suppose I have a car who’s train weight is 3499kg with the 1385kg  MTPLM Phoenix who’s OUTSIDE sticker shows an MTPLM of 1382kg.  I am, at that point, legal, BUT if the VOSA man knows about the gas locker sticker and goes by THAT figure I could, in theory, have a gross train weight in excess (by 68kg) of 3500kg and THAT could possibly mean I don’t have the correct driving licence even though it’s the same caravan! 

 

This to me is the key question.    Could you unwittingly exceed the 3500kg train weight limit.   It might be that Vosa don't care much and might look the other way.    An insurance company if you have just rolled £50K of kit might have a different view and motivation.    for me the regulation is clear and what is legal is also clear.   Others may disagree but I think that charging for such an "upgrade" plate is taking money under false pretences.

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Bailey change you for a weight upgrade?  I would think that the upgraded sticker they give you will have no standing in law but then you should know that.  :)   The correct weight plate is fixed to the chassis of the caravan and that is the one that counts.   The pack is just a money making paper exercise IMHO.  

Why not find the fixed mandatory plate on the chassis as more than likely it will show that the maximum weight of the chassis is 1450kg anyway?  It would be interesting to know either way.

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Type approval allows for downplating, so I suspect this is a case of design weight (gas locker) and plated weight (by door).  The plated weight is enforceable.  

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There have been several threads on this topic on both this and other forums.

The DVLA (or whatever they are called this week!) position seems to be that you can use either with two provisos:-

 

1. At any inspection the plate in the locker may need to be pointed out to the official concerned, as he/she is likely to take the first one he/she sees at face value.

2. You cannot use the lower figure for "B only " licence purposes and the higher one for loading purposes.

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36 minutes ago, handyandy said:

Type approval allows for downplating, so I suspect this is a case of design weight (gas locker) and plated weight (by door).  The plated weight is enforceable.  

If it is a sticker which can be removed, I am certain that it cannot be used in any prosecution and is only a guideline set by the manufacturers which is why in many cases you can upgrade the MTPLM as a paper exercise.   However the fixed plated weight on the chassis which cannot be removed is the plate that counts if stopped by VOSA.

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36 minutes ago, Stevan said:

There have been several threads on this topic on both this and other forums.

The DVLA (or whatever they are called this week!) position seems to be that you can use either with two provisos:-

 

1. At any inspection the plate in the locker may need to be pointed out to the official concerned, as he/she is likely to take the first one he/she sees at face value.

2. You cannot use the lower figure for "B only " licence purposes and the higher one for loading purposes.

 

You are, of course, right but it would be interesting were I to be stopped.   No plate in locker and external plate changed 'at will' by my dealer.   The latter because, Vanmaster are not (were not in previous guise) members of the NCC.

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1 hour ago, Durbanite said:

Bailey change you for a weight upgrade?  I would think that the upgraded sticker they give you will have no standing in law but then you should know that.  :)   The correct weight plate is fixed to the chassis of the caravan and that is the one that counts.   The pack is just a money making paper exercise IMHO.  

Why not find the fixed mandatory plate on the chassis as more than likely it will show that the maximum weight of the chassis is 1450kg anyway?  It would be interesting to know either way.

 

The valid weight is not the one on the chassis because that is applied by the Stage 1, i. e. chassis manufacturer. The plate that counts is the type approval plate applied by the caravan manufacturer at final stage of build and that wil normally be somewhere on the body.

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FWIW . .....

Thanks for this information.

New Caravan weights are dropping aren't they or is it  just new stickers ???

We did the FOC Elddis 'upgrade' with just a new sticker - zero physical changes. Assume this puts our van & it's axle back to its actual design weight  - I'd better check based on comments !

Was told by Dealer that Elddis like others are also doing the paper (sticker) downplating to keep their weights in-line with marketplace - forget about any of the increased payload issues and mis-leading customers.

Long overdue that there was some exposure to this scam & really is time this fiasco was stopped or made clearer for all to see & properly understood.   Rant over.

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EU type approval requires a plate with manufacturer and vin number and type approval number and maximum gross and axle weights .

 

Not sure how a plate with just a MAM and nothing else has any meaning in law .  

 

 

Dave

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3 hours ago, handyandy said:

Type approval allows for downplating, so I suspect this is a case of design weight (gas locker) and plated weight (by door).  The plated weight is enforceable.  

But which plate is the one that carries the legally enforceable information (I suspect it’s the one in the gas locker because that is the one that will also show the VIN number and various axle weights) But of course you need to know it’s there. Maybe THATS why it’s hidden away??

 

2 hours ago, Stevan said:

There have been several threads on this topic on both this and other forums.

The DVLA (or whatever they are called this week!) position seems to be that you can use either with two provisos:-

 

1. At any inspection the plate in the locker may need to be pointed out to the official concerned, as he/she is likely to take the first one he/she sees at face value.

2. You cannot use the lower figure for "B only " licence purposes and the higher one for loading purposes.

That’s all well and good BUT what figure do you use if you only have a Cat B licence! If you buy on the information on the external plate (which the vast majority of buyers would do) it’s possible that  the one inside the gas locker, with the higher weight would cause you to be (totally unwittingly) over on permitted gross train weight!  Also that enables manufacturers to charge for an upgrade when none is ACTUALLY needed (due to the higher MTPLM shown on the “less visible” plate)

 

2 hours ago, Lutz said:

 

The valid weight is not the one on the chassis because that is applied by the Stage 1, i. e. chassis manufacturer. The plate that counts is the type approval plate applied by the caravan manufacturer at final stage of build and that wil normally be somewhere on the body.

 

Exactly!!

 

BUT if there are two stickers, showing different weights, which one is to be believed! 

 

If its possible to have your caravan weight limit uprated by JUST a paper exercise it doesn’t take a genius to work out that the (uprated) weight is the one that the one that COULD  have been applied at the outset. So what, if I pay for an “upgrade” am I actually paying for?

 

I know there are certain motorhomes that leave the factory plated at around 3850kg (in excess of Cat B licence entitlement) that can be DOWN 

plated to 3500Kg to get under the Cat B licence limitation. It’s EXACTLY the same vehicle, the only thing that’s changed is the plate but, and it’s a very important but, the new plate has to contain the vehicles VIN number, and the various permitted axle weights.  That way it’s unique to that individual vehicle and not every one of that model.  

 

So, in theory, EXACTLY the same process could be applied IN REVERSE to uprate a caravan BUT the “new and uprated” plate that Bailey supply ONLY shows the caravan model and the higher gross weight. It doesn’t identify an individual caravan. I know this for a fact because I uprated my Bailey Olympus a couple of years ago (it didn’t have a gas locker sticker, I did check) So what’s to stop me peeling one off another (“uprated”) Phoenix and putting it on mine? It’s a generic not item specific sticker!!

 

An interesting conundrum and, much to Mrs Plodd’s annoyance, One I am determined to get some answers too. My gut feeling is that the caravan makers are, shall we say, being somewhat economical with the truth about the MTPLM of their products.

 

Andy

 

 

 

19 minutes ago, CommanderDave said:

EU type approval requires a plate with manufacturer and vin number and type approval number and maximum gross and axle weights .

 

Not sure how a plate with just a MAM and nothing else has any meaning in law .  

 

 

Dave

 

My point exactly, please see above

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8 minutes ago, Mr Plodd said:

But which plate is the one that carries the legally enforceable information (I suspect it’s the one in the gas locker because that is the one that will also show the VIN number and various axle weights) But of course you need to know it’s there. Maybe THATS why it’s hidden away??

 

That’s all well and good BUT what figure do you use if you only have a Cat B licence! If you buy on the information on the external plate (which the vast majority of buyers would do) it’s possible that  the one inside the gas locker, with the higher weight would cause you to be (totally unwittingly) over on permitted gross train weight!  Also that enables manufacturers to charge for an upgrade when none is ACTUALLY needed (due to the higher MTPLM shown on the “less visible” plate)

 

 

Exactly!!

 

BUT if there are two stickers, showing different weights, which one is to be believed! 

 

If its possible to have your caravan weight limit uprated by JUST a paper exercise it doesn’t take a genius to work out that the (uprated) weight is the one that the one that COULD  have been applied at the outset. So what, if I pay for an “upgrade” am I actually paying for?

 

I know there are certain motorhomes that leave the factory plated at around 3850kg (in excess of Cat B licence entitlement) that can be DOWN 

plated to 3500Kg to get under the Cat B licence limitation. It’s EXACTLY the same vehicle, the only thing that’s changed is the plate but, and it’s a very important but, the new plate has to contain the vehicles VIN number, and the various permitted axle weights.  That way it’s unique to that individual vehicle and not every one of that model.  

 

So, in theory, EXACTLY the same process could be applied IN REVERSE to uprate a caravan BUT the “new and uprated” plate that Bailey supply ONLY shows the caravan model and the higher gross weight. It doesn’t identify an individual caravan. I know this for a fact because I uprated my Bailey Olympus a couple of years ago (it didn’t have a gas locker sticker, I did check) So what’s to stop me peeling one off another (“uprated”) Phoenix and putting it on mine? It’s a generic not item specific sticker!!

 

An interesting conundrum and, much to Mrs Plodd’s annoyance, One I am determined to get some answers too. My gut feeling is that the caravan makers are, shall we say, being somewhat economical with the truth about the MTPLM of their products.

 

Andy

 

 

 

 

My point exactly, please see above

For the main UK brands the plate inside the locker is the statutory plate, and the plate by the door is merely an NCC plate.

By concession the DVLA (or whatever it is called this week) will use the NCC plate for B only licence purposes provided that you are not relying on the statutory plate for loading purposes, By buying the upgrade you are paying for the convenience of having the two plates agreeing with each other!

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13 minutes ago, Stevan said:

For the main UK brands the plate inside the locker is the statutory plate, and the plate by the door is merely an NCC plate.

By concession the DVLA (or whatever it is called this week) will use the NCC plate for B only licence purposes provided that you are not relying on the statutory plate for loading purposes, By buying the upgrade you are paying for the convenience of having the two plates agreeing with each other!

 

That makes perfect sense! 

 

But it wouldn’t it be nice if the manufacturers made that clear to everyone at the time of purchase?

 

I will wait and see if Bailey come back with a similar explanation.  

 

Andy

Edited by Mr Plodd

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2 minutes ago, Mr Plodd said:

 

That makes perfect sense! But it’s a tad naughty of Bailey’s to charge for an upgrade.  

 

I will wait and see if Bailey come back with a similar explanation.  

 

Andy

Andy don't you still have connections either through the police or elsewhere where you can get an answer regarding the weight plates direct from the horse's mouth?

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Just now, Durbanite said:

Andy don't you still have connections either through the police or elsewhere where you can get an answer regarding the weight plates direct from the horse's mouth?

Sadly I no longer have any contacts to use, but I intend taking the matter up with VODA once (IF) I have had a full answer from Bailey and I can provide photographs of both plates in my new caravan, but delivery isn’t until March!

 

Andy

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The plate with a lower weight plate would require a type approval number as the caravan has to be submitted for type approval at different weight values .

 

This was raised a few years ago on here about down plating for B licence and was raised with Ivor Williams and they replied in a Email that  they can't unless it has the type approval .

 

Andy has raised this issue a few times for a few years about having two plates and which one is legal showing different Mtplm . .

 

 

 

Dave

 

 

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Recently some UK manufacturers have taken a slightly different tack, with Hymer UK (Elddis/Compass/Buccaneer) and Lunar now sporting  just an external plate but separating the NCC figures and the mandatory information with a line. This means that in their case one plate has two MTPLM's on it, unless it's been upgraded, when both MTPLM's will read the same.

 

This is the first I've ever heard of the DVLA giving a 'concession' to UK caravan makers. I suspect they know very little, if anything about the way UK vans are down plated.

 

 

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The regulations are clear, it is in Bailey’s case the gas locker that is the statutory plate, the one that is compliant, with the regulations whether you agree with them or not.  The U. K. manufacturers understand the regulation. Because they tried to have it changed. There was a concession to them by allowing them to have the statutory plate affixed at the point of sale to allow  a low mptlm if the first owner wanted.  Obviously this was too much like hard work for the U. K. industry so the current persists.  You will notice that the representative absolutely failed to answer the question about legality.  

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1 hour ago, Mr Plodd said:

 

That makes perfect sense! 

 

But it wouldn’t it be nice if the manufacturers made that clear to everyone at the time of purchase?

 

I will wait and see if Bailey come back with a similar explanation.  

 

Andy

 

I suggest you check your certificate of conformity. That tells you the legal weight plate is in the gas locker.

14 minutes ago, Steamdrivenandy said:

Recently some UK manufacturers have taken a slightly different tack, with Hymer UK (Elddis/Compass/Buccaneer) and Lunar now sporting  just an external plate but separating the NCC figures and the mandatory information with a line. This means that in their case one plate has two MTPLM's on it, unless it's been upgraded, when both MTPLM's will read the same.

 

This is the first I've ever heard of the DVLA giving a 'concession' to UK caravan makers. I suspect they know very little, if anything about the way UK vans are down plated.

 

 

 

Er no. There is only one MTPLM on the Elddis plate, even if it has been upgraded which this one had37363082_Elddislabel.thumb.jpg.264a83347886dc59996cdd88542a5a0a.jpg:

 

 

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How many manufactures use this method of plating . I don’t think Lunar do.  

 

Anyway, caravans are not multistage builds so there should be no plate as such on the chassis.  Alko will supply the chassis in component form and these will have approvals rather than the chassis as a whole.  

 

The statutory plate is there for type approval purposes. A sticker is permitted for this as it is for information purposes only. The stamped vin in the chassis is there for identification.  

 

So a caravan is type approved to say 1450kg. The statutory plate will show this weight and maximum axle, nose weights.  

 

What happens after it has it has been type approved is up to the manufacturer. If they want to downplate it they can. They could uprate it too if they wanted to, providing it is technically possible.  All that is needed to change the weight of an O2 trailer is a paper trail, should it ever get asked for.  If a different weight to that shown on the statutory plate is affixed to the vehicle and bears the manufacturers name it is highly likely it would be legally binding. It is basically the manufacturer saving that the vehicle is safe to be used on the road at this weight.  

 

The thing to remember is that as O2 trailers are not registered in the UK it is up to the suppler to keep records. I would imagine that these records would be updated when a weight upgrade is ordered. If not, if any technical official was to contact Bailey for confirmation of weight the lower weight would be quoted.

 

The motorhome example above is a good one. Even if a motorhome is type approved at 3850kg and then down plated to 3500kg by the manufacturer it would get registered as a 3500kg vehicle. This would be the enforceable limit and would be what comes up is the number plate ever gets zapped. It would be easy to uprate it back up to 3850kg again in the future if need be, using the original type approval as evidence.   

 

 

 

 

Edited by handyandy

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24 minutes ago, handyandy said:

 

Anyway, caravans are not multistage builds so there should be no plate as such on the chassis.  Alko will supply the chassis in component form and these will have approvals rather than the chassis as a whole.  

 

 

Caravans are multistage builds. Unless AlKo supply only components of the chassis, but not a complete chassis assembly, the chassis itself will have been type approved by AlKo as the Stage 1 manufacturer.

 

Any subsequent downplating or up plating must be covered by the original type approval by allowing a range of MTPLM's in the actual type approval rather than just one value. Otherwise, the manufacturer would have to have the caravan resubmitted for type approval with the revised figures.

Edited by Lutz

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Yes Alko supply the chassis in component form. They have separate approvals for the hitch head, overrun control device, a frame and brake. They will have a brake calculation to prove compatibility.  

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My Bailey has the tamper-proof sticker inside the gas compartment that states 1300kg (1242kg on the axle, 58kg on the nose from memory).  In addition to this it has the sticker on the side showing the brochure figures for the MTPLM etc, when I paid for the upgrade I received a certificate and a replacement sticker on the side which has taken the MTPLM to 1300kg (I think it was 1238kg before) - no doubt I could probably argue at being between the two figure without the upgrade based on the gas locker sticker but for simplicity everything I have now has the revised figure on it.

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Your gas locker plate is an example of when Bailey appeared to not understand the purpose of the VIN plate Frank. They appeared to alight upon a random figure for the noseweight and then took it away from the MTPLM. For some reason neither the axle weight or the noseweight were what is legally required which is relevant weight limit for the noseweight and axle.  More recently they've changed and now show the relevant limits. I can only think that whoever looked after compliance at Bailey had totally misunderstood the Type Approval labelling requirement.

 

And on the plate shown by TB, the top figure is the caravan's maximum weight and below the line is the same MTPLM as the van has been upgraded. If it hadn't been upgraded the top figure would still show 1350kg but the MTPLM below the line would be the lower 'allocated' or sales brochure figure. 

 

 

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