Caravan gross weight, a response from Bailey!

[CommanderDave]

1 hour ago, Grandpa Steve said:

 

 

 

 

 

If you look at a car there is only one statutory plate fitted which carries either 3 or 4 weights (3 if it can't be used to tow), so no opportunity for confusion.

 

 

Which what I tried to explain the plating regulations . The plate with the required information and layout meets EU type approval and then the plate is absorbed into UK regulations under the RTA schedule 8 for road traffic enforcement .

 

I have EU type approval trailers and the type approval plate with a  maximum weight is used then for UK road regulations .

 

IMO to have lower weight the manufacturer has to make a lower maximum weight declaration on the type approval plate which would then be used under the RTA for enforcement .

 

 

 

Dave

Edited December 4, 2018 by CommanderDave

[SamD]

1 hour ago, Stevan said:

Yes but no but. ...

Licence provisions are not related to actual weights but are related to plated weights and it is the ambiguity of the plated weights that is the whole point of this thread.

The police are quite interested overloading by exceeding the plated numbers, DVSA are more interested in whether the licence matches the plates.

In theory, an outfit could be overloaded by reference to the door plate but within limits by the locker plate, whilst at the same time be within the B only limit by the door plate but outside it by the locker plate.

 

Agreed but I said it in shorthand.

[Mr Plodd]

4 hours ago, Stevan said:

 

The police are quite interested overloading by exceeding the plated numbers, DVSA are more interested in whether the licence matches the plates.

 

 

DVSA are totally uninterested in driving licence regs as they are not the enforcement agency for them. That’s down to the Police.

The Police are interested in driving licence regs AND any weight offences.  

 

4 hours ago, Stevan said:

 

In theory, an outfit could be overloaded by reference to the door plate but within limits by the locker plate, whilst at the same time be within the B only limit by the door plate but outside it by the locker plate.

 

VERY well explained indeed 

 

Andy

[Stevan]

19 minutes ago, Mr Plodd said:

 

DVSA are totally uninterested in driving licence regs as they are not the enforcement agency for them. That’s down to the Police.

The Police are interested in driving licence regs AND any weight offences.  

 

I stand corrected!

[Mr Plodd]

Upate time again!!!

 

I have now had a response from the NTTA, it’s below, alongbwith my reply to them.  Like most email trails you need to read it from the bottom up. I have deleted personal and unnecessary information.

 

 

 

Hi and thanks for the reply. However it doesn’t actually answer the question I asked and is somewhat ambiguous.

 

When you say “legal weight should be displayed on the exterior of the vehicle” and “they will only be looking at the plated weights displayed” which IS the “plated weight”? As there are TWO displayed

 

The one inside the gas locker, which I understand to be the “statutory plate” which is a legal requirement on all vehicles and contains all of the information that is required under The Road Vehicle (Approval) Regulations 2009 (as detailed below) 

 

 

 

Schedule 4, Part 2, Section 1

 

18. Plates (statutory)

1. The technical provisions of Directive 76/114/EEC as last amended by Directive 78/507/EEC.  

2. Where the vehicle is the subject of a multi stage build a plate is required on completion of each stage as appropriate.  

 

and Annex 1 Part A of 19/2011/EEC (an amendment of 76/114/EEC) says:

 

2. Information to be mentioned on the manufacturer’s statutory plate

2. 1. The following information shall be printed indelibly on the manufacturer’s statutory plate in the order listed:

(a) the manufacturer’s company name;

(b) the whole vehicle type-approval number;

(c) the vehicle identification number;

(d) the technically permissible maximum laden mass;

(e) the technically permissible maximum mass of the combination;

(f) the technically permissible maximum mass on each axle listed in order from front to rear.  

2. 2. The height of the characters shall not be less than 4 mm.  

3. Specific provisions

3. 1. Trailers

3. 1. 1. In the case of a trailer, the technically permissible maximum static vertical mass on the coupling point shall be mentioned.  

3. 1. 2. The coupling point shall be deemed the first axle and be numbered ‘0’.

3. 1. 3. The first axle shall be numbered ‘1’, the second ‘2’ and so on, followed by a hyphen.

3. 1. 4. The mass of the combination referred to in point 2. 1.(e) shall be omitted.

 

OR

 

is it the external decal which only contains SOME of the information and in particular does NOT show the various axle weights (as below) please note the below is from a difference caravan to the one I am enquiring in respect of.  

 

 

 

 

 

Please can you specify which one I should treat as the actual MTPLM The statutory plate which shows an MTPLM of 1450kg, or the external decal similar to the one above that shows 1382Kg. It VERY clearly cannot be both!  

 

The “statutory plate” inside the gas locker is tamperproof whereas the one shown above is easily removable.

 

When you say “I suggest that you cover the other plate” specifically WHICH plate, the one in the gas locker or the external one should I cover up?

 

ALSO when you say “I suggest that you cover the other plate” specifically WHICH plate, the one in the gas locker or the external one?

 

I am sorry if this seems somewhat convoluted but I am trying to get a definitive answer and the manufacturer simply skirts around the issue without giving me a definitive answer.  

Andy Culley

 

 

On 5 Dec 2018, at 16:29, nigel@towing-solutions. co. uk wrote:
 

Dear Mr. Culley,

 

Further to your question regarding the caravan weights.

 

Your legal weight should be displayed on the exterior of the caravan that the traffic authorities can read.   If they wish to check your weight beyond the plates of the vehicle or the caravan then they would physically weigh you and compare this against the Gross Train Weight.   In the example you quote for the licence then they will only be looking at the plated weights displayed.   

 

Unfortunately because this could be ambiguous when being checked by the authorities can I suggest that you cover the other plate and work to the weights of the MGVW.   This is in effect ‘down plating’ your caravan capacity.   Please note that you must adhere to the weight requirements of the plate that is displayed.

 

I hope this answers your question.

 

Regards

 

Nigel D. Lea

 

Towing Solutions Limited
Tel: +44 (0)1625 433251
Fax: +44 (0)8712 456686
Email: mail@towing-solutions. co. uk
Web: http://www. towing-solutions. co. uk
Location: Macclesfield, Cheshire. SK11 7RN 
  
Towing Solutions Limited is registered in England 4257932 with EC VAT Number GB 776 9961 49

 ------------------------------------

 

Julie Pywell

Administrative Assistant

National Trailer and Towing Association Ltd

 

Carriage Court, Welbeck, Worksop, Nottinghamshire, S80 3LR

Web: www. ntta. co. uk<http://www. ntta. co. uk/>

 

[LinkedIn_Logo]<https://www. linkedin. com/company/national-trailer-and-towing-association-ntta->     [Facebook_Logo] <http://www. facebook. com/nttauk>      [Twitter_Logo] <http://www. twitter. com/ntta_uk>

 

Any advice given and opinion expressed is for informational purposes only and should not be relied on as legal advice. Interpretation of the law is a matter for the courts. You may need to seek independent expert and/or legal advice to assist you.

 

National Trailer and Towing Association Ltd. is a limited company registered in England and Wales. Registered number: 01519120. Registered office: Carriage Court, Welbeck, Worksop, Nottinghamshire, S80 3LR

 

[NTTA-35th-email]<http://www. ntta. co. uk/>

 

From: No Reply <noreply@ntta. co. uk>

Sent: 05 December 2018 11:19

To: Info @ NTTA <info@ntta. co. uk>

Subject: Enquiry - NTTA

 

 

Thank you Andrew for contacting NTTA. We aim to respond to your query / question within 48 hours.

 

Contact: Andrew xxxxxx

 

Dear Sir

I contacted you on 27 November via this contact system with a query as to which of two differing weights that are shown on a particular caravan is the legally enforceable one. There is one plate in the gas locker which shows the manufacturer, the type approval number,the TIN (VIN) the various max axle weights and MGVW. There is an additional external decal which shows just the manufacturer, the caravan model name, the MRO, the MTPLM and the tyre pressures.

I am somewhat disappointed not to have heard back from yourselves as your auto response said you aim to reply within 48 hours. My question is which one I should treat as the legal MTPLM. I am asking this question because of the category B licence restrictions. The lower MTPLM shown on the outside puts my rig under 3500Kg gross but the internal (more detailed) plate puts it over 3500Kg so should I get stopped which one is the legally enforceable one as clearly a caravan cannot have two maximum weights.

 

 

So, yet again a bit of a fudge r

 

Andy

[fraser600]

What ? Cover it up ? Wow,  that's the best answer yet . Obviously has not got a clue,  

[Guest]

Their disclaimer is very clear which bring me back to my suggestion the only way to get an answer is from the enforcement agency.

 

Any advice given and opinion expressed is for informational purposes only and should not be relied on as legal advice. Interpretation of the law is a matter for the courts. You may need to seek independent expert and/or legal advice to assist you.

Edited December 5, 2018 by Guest

[Mr Plodd]

8 minutes ago, oldboy said:

Their disclaimer is very clear which bring me back to my suggestion the only way to get an answer is from the enforcement agency.

 

Any advice given and opinion expressed is for informational purposes only and should not be relied on as legal advice. Interpretation of the law is a matter for the courts. You may need to seek independent expert and/or legal advice to assist you.

 

As I am sure you appreciate I am VERY well aware of who can give me advice. I am ALSO well aware that it’s vital to garner as much information as possible and that is exactly what I am doing, trying to get any and all of the organisation with any involvement in caravans etc to supply me with THEIR take on the issue.

 

Having said that I would expect organisations such as the NTTA and NCC to have a comprehensive understanding of the various legislation, hence my response to the NTTA asking more questions.

 

The more time goes on the more I am thinking that the LEGALLY ENFORCABLE MGVW is what is shown on the statutory plate for the simple reason that’s the ONLY one that complies with The Road Vehicle (Approval) Regulations 2009 as detailed in my latest to the NTTA

 

Andy

[fred]

38 minutes ago, fraser600 said:

What ? Cover it up ? Wow,  that's the best answer yet . Obviously has not got a clue,  

Wow indeed.  

 

[Steamdrivenandy]

Have you tried the legal people at the CC or CCC Andy?

 

 As I mentioned earlier, when I contacted them last year the CC understood the quandary and said they were going to discuss it with 'the industry'. By that I presumed they meant the NCC. And just for clarity, neither club are members of the NCC. 

[Guest]

 I do appreciate that. personally, if it was me my first step would have been the enforcement agency to get a definitive answer that would have given me ammunition to query any anomaly from the manufacturer.

[Mr Plodd]

8 minutes ago, oldboy said:

 I do appreciate that. personally, if it was me my first step would have been the enforcement agency to get a definitive answer that would have given me ammunition to query any anomaly from the manufacturer.

 

I have indeed contacted the DFT (rather than DVSA) but sadly they quoted me a 20 working day response time. So in the meantime I will try the others.

 

The CC & CCC are the next on my list but I only have a certain amount of time in the day that I can devote to this!

 

Andy

[CommanderDave]

Bit of light reading . ?

 

https://publications. europa. EU/en/publication-detail/-/publication/d9d73ecb-54db-4af9-b718-3d6b6cf2d648/language-en

 

Locker manufacturers mandatory plate ?

Right Side Vin plate ?

 

Dave

Edited December 5, 2018 by CommanderDave

[Towtug]

40 minutes ago, CommanderDave said:

Bit of light reading . ?

 

https://publications. europa. EU/en/publication-detail/-/publication/d9d73ecb-54db-4af9-b718-3d6b6cf2d648/language-en

 

Locker manufacturers mandatory plate ?

Right Side Vin plate ?

 

Dave

From this regulation the Statutory plate has to be fixed in a conspicuous position. Conspicuous should mean somewhere external, not behind a panel or under a cover.  

The VIN referred to here is not a plate, the VIN should be cold punched or etched on a non removable part on the right side of the vehicle.

[Guest]

 

48 minutes ago, Towtug said:

The VIN referred to here is not a plate, the VIN should be cold punched or etched on a non removable part on the right side of the vehicle.

Correct.

[Lutz]

7 hours ago, Towtug said:

From this regulation the Statutory plate has to be fixed in a conspicuous position. Conspicuous should mean somewhere external, not behind a panel or under a cover.  

The VIN referred to here is not a plate, the VIN should be cold punched or etched on a non removable part on the right side of the vehicle.

 

I have yet to see a car where the statutory plate is conspicuously located on an exterior panel. Often you have to open the driver’s door first, release the bonnet and then search for the plate somewhere in the engine compartment - not much different to finding a plate in the front locker on a caravan.

 

Edited December 6, 2018 by Lutz

[Towtug]

1 hour ago, Lutz said:

 

I have yet to see a car where the statutory plate is conspicuously located on an exterior panel. Often you have to open the driver’s door first, release the bonnet and then search for the plate somewhere in the engine compartment - not much different to finding a plate in the front locker on a caravan.

 

I agree. They count conspicuous as something that is easy to see ie. in a door shut, or under bonnet, but not something that might require unloading to get to it such as a luggage space . I have accepted vehicles with Stat plates in the locker, but not if they are fitted behind a fixed bottle or tools etc.

[Mr Plodd]

The very interesting part for me is on page two, para 2 under definitions for the “Statutory plate” where it clearly states  “and provides the competent authorities with relevant information concerning the maximum laden mass “ 

 

Pretty clear don’t you think? No mention of any additional

plate.

 

On my car the statutory plate is a self adhesive decal in the drivers door shut! Hardly visible or conspicuous from the outside

 

Andy

 

 

 

 

Edited December 6, 2018 by Mr Plodd

[CommanderDave]

3 hours ago, Lutz said:

 

I have yet to see a car where the statutory plate is conspicuously located on an exterior panel. Often you have to open the driver’s door first, release the bonnet and then search for the plate somewhere in the engine compartment - not much different to finding a plate in the front locker on a caravan.

 

 

 

A lot of motor vehicles now have a VIN plate on the top of the dash and can be read through the windscreen ?

 

Weight plate in the door ? (Statutory)

 

 

Dave

Edited December 6, 2018 by CommanderDave

[Lutz]

17 minutes ago, CommanderDave said:

 

 

A lot of motor vehicles now have a VIN plate on the top of the dash and can be read through the windscreen ?

 

Weight plate in the door ? (Statutory)

 

 

Dave

 

The VIN plate is not the same as the statutory plate which requires a lot more information than just the VIN.

The VIN at the top of the dash is a relatively old US requirement which since has been adopted elsewhere.

Usually, the VIN is also to be found under the carpet on the inner sill or floor panel, next to the driver's or front passenger's seat.

[CommanderDave]

On my type approved trailer I have a mandatory plate with the manufacturers weight declarations ( shown as model C for 01-02 trailers in UK ) and also the VIN number struck into the drawbar itself next to the plate .

 

What can't understand is why we have this issue of different plating when we are all suppose to be singing from the same songsheet ?

 

 

Dave

Edited December 6, 2018 by CommanderDave

[Guest]

16 minutes ago, Lutz said:

 

The VIN plate is not the same as the statutory plate which requires a lot more information than just the VIN.

The VIN at the top of the dash is a relatively old US requirement which since has been adopted elsewhere.

Usually, the VIN is also to be found under the carpet on the inner sill or floor panel, next to the driver's or front passenger's seat.

 

There's a lot of hair splitting here, Dave clearly stated the VIN plate was visible on the dash, and the weight plate was on the door, so why point it out again?

[CommanderDave]

13 minutes ago, Grandpa Steve said:

 

There's a lot of hair splitting here, Dave clearly stated the VIN plate was visible on the dash, and the weight plate was on the door, so why point it out again?

 

The VIN they refer to the Vehicle Identity Number not necessary a plate that cold stuck into the chassis / shell on the assembly line that has to be it's individual number . Majority of motor vehicle have them by the edge of the windscreen inside as it not easy to cut out and replace or tamper with and on view .

 

 

Dave

Edited December 6, 2018 by CommanderDave

[Towtug]

12 minutes ago, CommanderDave said:

 

The VIN they refer to the Vehicle Identity Number not necessary a plate that cold stuck into the chassis / shell on the assembly line that has to be it's individual number . Majority of motor vehicle have them by the edge of the windscreen inside as it not easy to cut out and replace or tamper with and on view .

 

 

Dave

They also have to have it marked, etched or cold punched elsewhere on the right side of the vehicle.

[CommanderDave]

20 minutes ago, Towtug said:

They also have to have it marked, etched or cold punched elsewhere on the right side of the vehicle.

 

Majority cold punched I see for security and able to retrieve for forensics .

 

 

Dave

Edited December 6, 2018 by CommanderDave