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Mr Plodd

Caravan gross weight, a response from Bailey!

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2 hours ago, Durbanite said:

Dave states it is the CRiS number however this should apply to all trailers and not specifically caravans and what is to prevent another trailer have the same ID number unless the ID number was obtained from a national data base prior to being built?

 

Dave actually said "The CRiS system uses the Caravans 17 digit ID number" .

 

There is nothing to stop another trailer having the same ID, but an Ifor Williams looks a lot different to a Bailey Rimini :)

1 minute ago, Mr Plodd said:

 

Like I have already said, I am awaiting a reply from DFT.

 

I  don’t think there’s a lot of point  in asking the  NCC because they are the manufacturers trade body and probably the cause of all this uncertainty in the first place.  

 

I will will also contact the ACPO lead on Road Policing but first I need photographs of the two relevant decals/plates/stickers 

 

Andy

 

Not only does the caravan leak, the plating regime is also full of holes ;) 

 

...and don't get me started on leaked documents :ph34r:

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I am sure that your persistence has not gone unnoticed in the industry, Mr Plodd, but the implications can be quite tremendous and I suspect that the whole industry is going to fight tooth and nail not to be cornered into a position where they are forced to make a conclusive statement, as it might cost them dearly. I can even imagine that some in the industry who see the issue differently, and I am sure there are those, are being put under pressure to stick to the guns with the rest.

6 minutes ago, Grandpa Steve said:

 

Dave actually said "The CRiS system uses the Caravans 17 digit ID number" .

 

There is nothing to stop another trailer having the same ID, but an Ifor Williams looks a lot different to a Bailey Rimini

 

But Ifor Williams will have a different number series assigned to them than Bailey.

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It would be interesting to know whether the caravan makers employ their own legal advisers/consultants on such matters or whether they rely on NCC guidance. I have a suspicion that the latter may be the case because all the UK manufacturers that are NCC members initially moved to plates in the gas locker at the same time. Surely, one, or more of them would have put the plate somewhere else, if they were getting independent advice?

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Just now, Lutz said:

I am sure that your persistence has not gone unnoticed in the industry, Mr Plodd, but the implications can be quite tremendous and I suspect that the whole industry is going to fight tooth and nail not to be cornered into a position where they are forced to make a conclusive statement, as it might cost them dearly. I can even imagine that some in the industry who see the issue differently, and I am sure there are those, are being put under pressure to stick to the guns with the rest.

 

I started this whole exercise to try and get the situation clarified PARTICULARLY in respect of Cat B licence holders who could, very understandably, end up driving a rig outside their 3500Kg limit. It may well be that I have indeed identified something that “The industry” up until now hadn’t thought of. That doesn’t absolve them of responsibility though! 

 

I have REALLY got the bit between my teeth now (in case you hadn’t already realised it) and I am determined to do all that I can to get some form of definitive answer out of someone, be that the DFT, Police, DVSA.  

 

Watch this space.  

 

Andy

 

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As I posted a day or so ago, the VIN number is allocated at the commencement of the build by the manufacturer. Each manufacturer has a set of ID no's that appear within the VIN which makes each number unique. It just so happens that CRIS have adopted the VIN as the means of registering a van on their system. It makes sense as there's no point in reinventing the wheel. 

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1 hour ago, Steamdrivenandy said:

As I posted a day or so ago, the VIN number is allocated at the commencement of the build by the manufacturer. Each manufacturer has a set of ID no's that appear within the VIN which makes each number unique. It just so happens that CRiS have adopted the VIN as the means of registering a van on their system. It makes sense as there's no point in reinventing the wheel.  

 

 A Crusade indeed. ... :blink:

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1 hour ago, Mr Plodd said:

 

I started this whole exercise to try and get the situation clarified PARTICULARLY in respect of Cat B licence holders who could, very understandably, end up driving a rig outside their 3500Kg limit. It may well be that I have indeed identified something that “The industry” up until now hadn’t thought of. That doesn’t absolve them of responsibility though! 

 

I have REALLY got the bit between my teeth now (in case you hadn’t already realised it) and I am determined to do all that I can to get some form of definitive answer out of someone, be that the DFT, Police, DVSA.  

 

Watch this space.  

 

Andy

 

Perhaps your next missive to Bailey should be along the lines of.   As there seems to be a certain ambiguity whether or not the plate placed on the outside takes precedence over the statutory plate That is placed within the gas locker.   I would ask that you offer an indemnity in writing  to all owners.  To  cover all costs, in the admittedly unlikely event, that the mptlm shown on the  statutory plate and the accompanying  certificate of compliance,  is used used as the basis for a prosecution, or the refusal of an insurance claim.  

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Fred

 

I am sure we all know what sort of response I would get from Bailey in respect of your suggestion. 

 

Andy

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Are you saying that they might not be willing to stand by their claim that the plate on the outside is the definitive one?   Surely not. :D

 

Being cynical the very fact that they put a fully compliant plate in an appropriate position suggests to me that they know exactly what they are doing.  This has nothing to do with incompetence.  

 

 

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I am sure you are right Fred, the problem comes in trying to get any definitive response out of Bailey and they have very clearly shown they are NOT going to provide one.

 

I am currently working  on my next missive to the Compliance Engineer at Bailey, but the whole organisation would appear to masters in not ACTUALLY. answering embarrassing questions.

 

My own opinion is that the exterior plate is nothing more than a decorative item and the one in the gas locker is the important one that shows the ACTUAL (rather than the NCC’s estimated) MTPLM.  

 

Andy

 

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Ask for a copy of the C of C.  On it should be the Type Version and Variant, The MRO, the Actual Mass and the MTPLM

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I am sure a copy of CoC is issued with a new caravan in the manual pack which include gas and electric safety certificate.

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I’ve got a copy of my CoC to be honest I don’t recall it stating the MRO but I could be wrong.    It is unsurprisingly in German.   As Bailey vans are type approved in Luxembourg is the CoC in French?

 

Edit  I am talking about the CoC issued with the type approval.  Not any form of certification issued under the auspices of the NCC

Edited by fred

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35 minutes ago, fred said:

I’ve got a copy of my CoC to be honest I don’t recall it stating the MRO but I could be wrong.    It is unsurprisingly in German.   As Bailey vans are type approved in Luxembourg is the CoC in French?

 

Edit  I am talking about the CoC issued with the type approval.  Not any form of certification issued under the auspices of the NCC

C of C for type approval .

MRO is item 13 on Side 2.

MTPLM is item 16

Language can be any EU27.

 

 

Edited by Towtug

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1 hour ago, Mr Plodd said:

I am sure you are right Fred, the problem comes in trying to get any definitive response out of Bailey and they have very clearly shown they are NOT going to provide one.

 

I am currently working  on my next missive to the Compliance Engineer at Bailey, but the whole organisation would appear to masters in not ACTUALLY. answering embarrassing questions.

 

My own opinion is that the exterior plate is nothing more than a decorative item and the one in the gas locker is the important one that shows the ACTUAL (rather than the NCC’s estimated) MTPLM.  

 

Andy

 

Compliance🤔Engineers🤔, wishful thinking😂

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2 hours ago, Towtug said:

C of C for type approval .

MRO is item 13 on Side 2.

MTPLM is item 16

Language can be any EU27.

 

 

 

And actual mass is item 13. 2

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Perhaps Towtug will confirm, but I assume that, in cases of dispute or conflict, the Certificate of Conformity is the document that takes precedence over any plate, whether statutory or NCC.

In other words, if the manufacturer has made a mistake in printing the statutory plate and it doesn’t agree with the Certificate of Conformity, which of the two is definitive?

Edited by Lutz

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It does seem quite a strange system the UK has with two plates, I’ve looked inside and out on mine and all I can find is a plate inside the front locker with the Chassis number, Max Axle Weight and Noseweight on it, no plates are visible anywhere on the exterior.  I hope this will suffice if the authorities check me when I’m visiting the UK.

D2E8449C-23F9-427A-ACDB-EB9C45978002.png

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5 minutes ago, Borussia 1900 said:

It does seem quite a strange system the UK has with two plates, I’ve looked inside and out on mine and all I can find is a plate inside the front locker with the Chassis number, Max Axle Weight and Noseweight on it, no plates are visible anywhere on the exterior.  I hope this will suffice if the authorities check me when I’m visiting the UK.

D2E8449C-23F9-427A-ACDB-EB9C45978002.png

Even yours doesn't comply with the Statutory plates regulation as the axle masses are not in the correct order, should be

2000kg

0 - 100kg

1 - 2000kg

2- 

 

PS I'm paid to be pedantic :)

 

I don't think the authorities here will be too concerned though.

 

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3 minutes ago, Towtug said:

Even yours doesn't comply with the Statutory plates regulation as the axle masses are not in the correct order, should be

2000kg

0 - 100kg

1 - 2000kg

2- 

 

PS I'm paid to be pedantic :)

 

I don't think the authorities here will be too concerned though.

 

Well spotted :D

 

Perhaps its only got one plate because the registration system is different here? The caravan has its own number plate which matches the Fahrzeugschein (registration document) and it's registered/inspected/insured similar to a car, I believe that's not the case in Britain.

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8 hours ago, Lutz said:

Perhaps Towtug will confirm, but I assume that, in cases of dispute or conflict, the Certificate of Conformity is the document that takes precedence over any plate, whether statutory or NCC.

In other words, if the manufacturer has made a mistake in printing the statutory plate and it doesn’t agree with the Certificate of Conformity, which of the two is definitive?

Not sure of the legality, as the Plates are covered by a regulation, whereas the C of C is covered by the framework directive and implementing regulation.

So both are legally required but nothing tells me what should have precedence.

 

What it does say is:

The certificate of conformity is a statement delivered by the vehicle manufacturer to the buyer in order to assure him that the vehicle he has acquired complies with the legislation in force in the European Union at the time it was produced.
The certificate of conformity also serves the purpose to enable the
competent authorities of the Member States to register vehicles without
having to require the applicant to supply additional technical documentation.
For these purposes, the certificate of conformity has to include:
(a) the Vehicle Identification Number;
(b) the exact technical characteristics of the vehicle (i. e. it is not permitted
to mention any range of value in the various entries).

 

So on the basis of the last paragraph which I've highlighted, I would argue that any difference between the figures on the C of C and any plating of the vehicle is not allowed.

 

If you think about it what would be the point of specifically defining so much information on the C of C  ostensibly for the purpose of registration, only to put something different on the vehicle.

11 hours ago, bookandym said:

Compliance🤔Engineers🤔, wishful thinking😂

Bit rude!

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23 minutes ago, Borussia 1900 said:

Well spotted :D

 

Perhaps its only got one plate because the registration system is different here? The caravan has its own number plate which matches the Fahrzeugschein (registration document) and it's registered/inspected/insured similar to a car, I believe that's not the case in Britain.

 

Plating requirements are independent of registration, but of course the details shown on the registration document must agree with what is on the plate. Foreign authorities would ignore any different MTPLM that may be shown on a second label next to the door because it would not be the same as the Certificate of Conformity which would have to be submitted when a caravan is registered for the first time.

 

16 minutes ago, Towtug said:

 

So on the basis of the last paragraph which I've highlighted, I would argue that any difference between the figures on the C of C and any plating of the vehicle is not allowed.

 

 

Of course, but humans make mistakes (we have had several incidents reported in this forum of V5c's being issued with incorrect details) and my question was aimed at clarifying what would happen if the details on the statutory plate don't agree with the Certificate of Conformity. Which of the two would have to be corrected? I would assume the plate.

 

Edited by Lutz

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35 minutes ago, Towtug said:

Even yours doesn't comply with the Statutory plates regulation as the axle masses are not in the correct order, should be

2000kg

0 - 100kg

1 - 2000kg

2- 

 

PS I'm paid to be pedantic :)

 

I don't think the authorities here will be too concerned though.

 

As Morcambe and Wise might of said.   All the right numbers though not neccesarily in the right order.  

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12 hours ago, Towtug said:

C of C for type approval .

MRO is item 13 on Side 2.

MTPLM is item 16

Language can be any EU27.

 

 

I've been following this thread with interest. I've just checked the CofC issued by Swift and it is spot on according to the above. However, of interest to the discussion I quote from my CofC. ..…

"0. 6 Location and method of attachment of the Statutory Plates: On the bulkhead inside the LPG housing attached by adhesive.

Location of the Vehicle identification Number: Right hand side of the A frame"

I have no idea what the plate on the body by the entrance door is there for, but as the details on it are correct I'm not bothered.

My opinion then is that the only legal plate on our Swift caravan is the one described in the CofC = on the bulkhead.

Mr Plodd could be uttering those immortal words "Ello,ello,ello" to some unsuspecting B licence holders.

Edited by Ern

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55 minutes ago, Lutz said:

 

Plating requirements are independent of registration, but of course the details shown on the registration document must agree with what is on the plate. Foreign authorities would ignore any different MTPLM that may be shown on a second label next to the door because it would not be the same as the Certificate of Conformity which would have to be submitted when a caravan is registered for the first time.

 

 

Of course, but humans make mistakes (we have had several incidents reported in this forum of V5c's being issued with incorrect details) and my question was aimed at clarifying what would happen if the details on the statutory plate don't agree with the Certificate of Conformity. Which of the two would have to be corrected? I would assume the plate.

 

I've just had to act for someone trying to register a UK car in Germany. One digit from the VIN on the V5c was wrong, despite having the car TUV would only accept the C of C as evidence to correct it.

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