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Caravan gross weight, a response from Bailey!


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IMO I see this as a EU plate and EU regulations and a no meaning NCC plate stuck on the side . UK governing bodies has no powers to decide on EU laws and regulations and these caravans are taken abroad into Europe by owners  .   

 

Stopped abroad and the police will want see the EU type approval plate ?

 

Dave

 

Jeep Commander 3. 0 V6 CRD

Isuzu D- Max Utah Auto

Elddis Crusader Storm 2000 Kgs, Unipart Royal Atlas Mover .

 

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10 hours ago, CommanderDave said:

IMO I see this as a EU plate and EU regulations and a no meaning NCC plate stuck on the side . UK governing bodies has no powers to decide on EU laws and regulations and these caravans are taken abroad into Europe by owners  .   

 

Stopped abroad and the police will want see the EU type approval plate ?

 

Dave

 

 

I'm repeating myself but, The NCC represent the manufacturers, the manufacturer has made a declaration  about that individual caravan to be XXXX MTPLM.

 

This is relayed to us the owner via the NCC own style sticker.

 

They have a legal right to downplate.

 

The technicality of what sticker has what on it and how, is deviating from this simple, and I mean really simple common practice.

 

 

 

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If the caravan builder has a legal right to downplate, why do they not fit the mandatory type approval plate with the lower MTPLM on it? Why fit two plates with differing MTPLM's, with no explanation documented and how does it square with type approval regulations that demand that only one plate can be legal? Surely a downplated wagon has a type approval format plate with the lower weights on it?

 

I've got nothing to do on this hot afternoon

but to settle down and write you a line.

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8 hours ago, Simple Life said:

They have a legal right to downplate.

I am definitely repeating myself here.  Which law/ regulation gives them this legal right to down plate?

 

Actually manufacturers can down plate in the sense that they don’t have to get type approval that is identical with the maximum loads.  It can be less.  Afaik they can have multiple type approvals with different weights for the same model.   They can then fit a specific statutory plate according to the customers wish.  

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8 hours ago, Simple Life said:

 

 

I'm repeating myself but, The NCC represent the manufacturers, the manufacturer has made a declaration  about that individual caravan to be XXXX MTPLM.

 

This is relayed to us the owner via the NCC own style sticker.

 

They have a legal right to downplate.

 

The technicality of what sticker has what on it and how, is deviating from this simple, and I mean really simple common practice.

 

Nobody is saying you can't down plate if done through the type approval process the issue is the official EU type approval plate in the locker showing the MAM of the trailer at a higher value .   

 

Dave

Jeep Commander 3. 0 V6 CRD

Isuzu D- Max Utah Auto

Elddis Crusader Storm 2000 Kgs, Unipart Royal Atlas Mover .

 

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40 minutes ago, Steamdrivenandy said:

If the caravan builder has a legal right to downplate, why do they not fit the mandatory type approval plate with the lower MTPLM on it? Why fit two plates with differing MTPLM's, with no explanation documented and how does it square with type approval regulations that demand that only one plate can be legal? Surely a downplated wagon has a type approval format plate with the lower weights on it?

 

Because the whole vehicle has been type approved at that weight, and that has to be displayed.

 

When the manufacturers doesn't take advantage of the whole vehicle approval by a declaration they cannot alter the whole vehicle approval plate, therefore a secondary plate is used to inform the user the vehicles declared usable weight.

 

If it was the other way around then the manufacturers would have to gain several type approvals, and then deliver to a customer a vehicle at the customers desired weight.

 

Easier to bung a new sticker on.

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7 minutes ago, Simple Life said:

Because the whole vehicle has been type approved at that weight, and that has to be displayed.

 

When the manufacturers doesn't take advantage of the whole vehicle approval by a declaration they cannot alter the whole vehicle approval plate, therefore a secondary plate is used to inform the user the vehicles declared usable weight.

 

If it was the other way around then the manufacturers would have to gain several type approvals, and then deliver to a customer a vehicle at the customers desired weight.

 

Easier to bung a new sticker on.

 

 

Introducing a usable weight plate is just saying for example if a trailer is plated with maximum weight of 1450 kg and then you introduce another plate saying you can only load to a lower value say 1400 kg is the same as trying to introduce " actuals" saying you can load to the lesser value of 1400 kg which is still illegal for B licence holders when the official plate still shows 1450 kg .

 

Dave

 

Jeep Commander 3. 0 V6 CRD

Isuzu D- Max Utah Auto

Elddis Crusader Storm 2000 Kgs, Unipart Royal Atlas Mover .

 

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8 hours ago, Simple Life said:

They have a legal right to downplate. 

 

I think if that statement could be substantiated then the discussion would be over.

 

John

Volvo V70 D3 SE (was Peugeot 4007, SsangYong Korando), Pulling a Lunar Clubman SI 2015. If you are depressed, you are living in the past. If you are anxious, you are living in the future. If you are at peace, you are living in the present.

 

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30 minutes ago, JCloughie said:

 

I think if that statement could be substantiated then the discussion would be over.

 

John

https://www. gov. uk/vehicle-weights-explained

 

 

Down-plating

If a vehicle is unlikely to be used at its potential maximum weight, it may be ‘down-plated’. This means that a lower weight is shown on the plate or sticker attached to the vehicle.

 

Edited by Simple Life
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17 hours ago, Mr Plodd said:

Latest from Bailey below!!

 

Good Afternoon,

As compliance engineer for Bailey of Bristol I have been asked to contact you regarding the below email conversation. I am responsible for European Whole Vehicle Type Approval and also NCC approval. Therefore I am best suited to answer your question.  

 

Gas locker plate

This plate shows the maximum load of the nose and the axles. This Is there purely for type approval purposes. The DVSA and all other authorities do not use this plate.  

 

Habitation door plate

This plate shows the MRO and MTPLM of the vehicle as calculated and ser buy the manufacturer of the vehicle. These figures are the ones that the owner/user of the vehicle must adhere to. These figures are the ones that the authorities will base any checks on. Failure to observe these figures will mean that the customer is using the vehicle illegally on a road. This will also breach the terms and conditions of the warranty making it invalid.  

 

Kind Regards 

Alexander Owen 

Compliance Engineer 

 

I

 

Andy

Has it been pointed out to Bailey that the sticker by the habitation door is not a statutory or mandatory plate according to current legislation?

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6 minutes ago, Simple Life said:

https://www. gov. uk/vehicle-weights-explained

 

 

Down-plating

If a vehicle is unlikely to be used at its potential maximum weight, it may be ‘down-plated’. This means that a lower weight is shown on the plate or sticker attached to the vehicle.

 

 

" On the plate " not another plate attached to the vehicle .

 

 

Dave

Jeep Commander 3. 0 V6 CRD

Isuzu D- Max Utah Auto

Elddis Crusader Storm 2000 Kgs, Unipart Royal Atlas Mover .

 

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10 minutes ago, Simple Life said:

Re read the Bailey reply.

 

 

I have again and  said on what grounds of EU regulations the statement is made that authorities do not use the EU type approval plate as a owner will possibly need to know when trying to convince a police officer in Europe if stopped ?

 

 

Dave

Edited by CommanderDave

Jeep Commander 3. 0 V6 CRD

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Elddis Crusader Storm 2000 Kgs, Unipart Royal Atlas Mover .

 

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34 minutes ago, CommanderDave said:

 

 

I have again and  said on what grounds of EU regulations the statement is made that authorities do not use the EU type approval plate as a owner will possibly need to know when trying to convince a police officer in Europe if stopped ?

 

 

Dave

I can only re describe the process, try a different tact.

 

EU plate is for the production run.

 

NCC plate is for the individual caravan.

 

The manufacturer downplates the individual caravan via a declaration  which is shown via the NCC plate.

 

And we are back where we started.

 

 

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Where is the regulations that state a NCC plate supersedes a EU mandatory plate backed by EU directives and EU regulations ?

 

That's what I am being told ?

 

Dave

 

 

Jeep Commander 3. 0 V6 CRD

Isuzu D- Max Utah Auto

Elddis Crusader Storm 2000 Kgs, Unipart Royal Atlas Mover .

 

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12 minutes ago, Simple Life said:

I can only re describe the process, try a different tact.

 

EU plate is for the production run.

 

NCC plate is for the individual caravan.

 

The manufacturer downplates the individual caravan via a declaration  which is shown via the NCC plate.

 

 

And we are back where we started.

 

 

 

 

Which is probably where some people in this thread would like it, as they can then Talk endlessly again in their circular argument.

At the end of the day, this pretty clear cut.  

A trailer can be legally down plated (which most caravans are).

This is shown on the plate by the habitation door.

A trailer requires a type approval, which is shown on the gas locker plate.

The weight used for legal reasons (because guess what, the trailer has been legally downweighted) is the one by the habitation door.

 

 

THE END (which is where we were 8 pages back).

Edited by warrenb
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I come back to the Type Approval regs say only one MTPLM must be exhibited and it must be to the prescribed format, with axle loads and VIN number etc.

 

If a van is downplated then the mandatory plate has to have the one and only MTPLM  on it. 

 

By inference a second plate that doesn't comply to the mandatory format surely cannot be legally relied upon. In effect it's just decoration. 

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I've got nothing to do on this hot afternoon

but to settle down and write you a line.

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"The weight plate in the locker is only for our purposes " . That would make a good legal defense for a owner .

 

So the maximum axle weights on the plate are only for their purposes ?

 

Dave

Edited by CommanderDave

Jeep Commander 3. 0 V6 CRD

Isuzu D- Max Utah Auto

Elddis Crusader Storm 2000 Kgs, Unipart Royal Atlas Mover .

 

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53 minutes ago, fraser600 said:

Screenshot_20181128-113116.jpg

Screenshot_20181128-113558.jpg

 

That is good stuff!  I had always assumed that the NCC were party to this subterfuge but it would appear from this that they agree with CT members (well most of us!)

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2 hours ago, Simple Life said:

https://www. gov. uk/vehicle-weights-explained

 

 

Down-plating

If a vehicle is unlikely to be used at its potential maximum weight, it may be ‘down-plated’. This means that a lower weight is shown on the plate or sticker attached to the vehicle.

 

 

Thanks for that.  But it still brings up questions.  

 

As most people struggle to keep their loads down to their caravans stated maximum.  To down plate on the basis that it’s UNLIKELY to to be used at its potential maximum is clearly very wrong.

 

A down loaded plate surely must match the set conditions for information and mounting.  (See SDA above).

 

Not yet convinced.

 

Looking at fraser600’s post.  It shows that the industry is confused, so what chance do we stand.

 

 

 

John

 

 

Volvo V70 D3 SE (was Peugeot 4007, SsangYong Korando), Pulling a Lunar Clubman SI 2015. If you are depressed, you are living in the past. If you are anxious, you are living in the future. If you are at peace, you are living in the present.

 

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17 hours ago, oldboy said:

I was only giving you an example of how a vehicle weight is determined. you are correct MTPLM- MIRO = payload( Miro + payload=MTPLM). 

I have read with interest this discussion but while at first sight the two equations quoted may appear the same this is not necessarily the case

Eq1 "MTPLM - MIRO = payload" is correct as it is the MTPLM that is fixed. Subtract from this the actual empty weight (MIRO) and what is left defines the maximum payload that can be added.

Eq2 "Miro + payload = MTPLM" is incorrect and should read "(Miro + payload) must not exceed MTPLM". Assuming that the MIRO for a given caravan is fixed, adding a variable payload to Eq2 implies that the MTPLM would also become a variable - and that is clearly not the case.

 

Moving on to the chassis. The MTPLM is a fixed maximum permitted weight, not necessarily the weight that it will actually be loaded to. Similarly the axle weights and tyre ratings can be higher than the declared MTPLM, but the lowest limit is the one that will define the maximum safe load. I once had a twin axle caravan with both axles rated at 750kgs. Theoretically therefore one would assume the MTPLM would be 2 x 750 = 1500kgs. but this was not the case. The actual MTPLM was 1300kgs. This was an allowance for the axles not necessarily sharing the load equally, and consequently the chassis' A-frame rating was reduced to 1300kgs presumably as it used less material and so saved both cost and weight.

 

But I digress:- The MTPLM shown in the locker is the maximum the caravan could possibly ever be loaded to. The sticker placed on the exterior of the bodywork by the caravan manufacturer is an exercise to make the caravan appeal to potential owners who may not be allowed because of licencing limitations, towcar train weight or other legally enforceable restrictions, to tow a given caravan at it's full potential weight.

 

Now the subjective bit:-

I can see no danger in reducing the declared MTPLM prior to the initial sale but once this is done in my opinion this should be fixed for the life of the caravan, and the plate containing all other legally required information should be amended to reflect this. If the manufacturer then wishes to fix a second, third or forth "sticker" elsewhere containing the identical information, then I see no problem with this either. If I were in a position of having a licence restriction of 3500kgs I most definitely would NOT buy a caravan where the MTPLM had been downrated by the caravan manufacture unless the original type approval plate reflected this lower limit, regardless of how many other stickers were on the caravan. 

 

Food for thought:-

A cross channel ferry is essentially a ship (the hull with engine, propulsion equipment etc) that carries a fixed payload (the superstructure including the car decks and passenger accommodation), and a variable payload (the cars and passengers).

Similarly a tourer comprises a trailer (chassis and running gear), a fixed payload (the caravan body and all fittings) and a variable payload (the user's possessions). The trailer will have a load limit that must not be exceeded by adding the caravan body and the user's contents. The trailer weight plus the bodywork weight becomes the MIRO, and when the payload (user's possessions) is added the total must not exceed the MTPLM.

 

Just my thoughts,

Gordon.

Fourwinds Hurricane 31D Motorhome. Also MGTF135 1. 8i Roadster (fun) & Volvo V70 3.2Ltr LPG (everyday car)
Unless otherwise stated, my posts will be my personal thoughts and have the same standing as any other member of Caravan Talk.

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We are learning a lot from what we are being told ?  DVSA and authorities will only use the plate on the side and the plate in the locker is only for their purposes .

 

Handy to know axle weights are not a legal  enforcement ?

 

 

Dave

Jeep Commander 3. 0 V6 CRD

Isuzu D- Max Utah Auto

Elddis Crusader Storm 2000 Kgs, Unipart Royal Atlas Mover .

 

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5 hours ago, Simple Life said:

I can only re describe the process, try a different tact.

 

EU plate is for the production run.

 

NCC plate is for the individual caravan.

 

The manufacturer downplates the individual caravan via a declaration  which is shown via the NCC plate.

 

And we are back where we started.

 

 

 

Wrong

 

The EU plate is also specific to the particular caravan because it must show the VIN.

 

The manufacturer cannot downplate only with a declaration. It must be accompanied by a new statutory weight (EU) plate.

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