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Mr Plodd

Caravan gross weight, a response from Bailey!

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24 minutes ago, Lutz said:

 

One should point out  that you are talking about 'Ministry plates' here which are only relevant to goods vehicles. The issue at hand is the statutory plate which is something else and applies to all vehicles, not just goods vehicles.

 

Exactly the issue IMO  is the statutory Vin plate and the plated mam as this can effect yes B licence but also drivers with B+E as the plated weight effects speed limits and tolls and bridge weight limits . What is the legality and owners defence it stopped and prosecuted ?

 

I just want to know where it states in regulations that police or authorities don't use the Vin plate but must use the plate on the side ?

 

Dave

Edited by CommanderDave

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33 minutes ago, oldboy said:

A licence tells you exactly what you can and can not drive.  

A driving licence tells you only what you can drive. I have had to "educate" quite a few people who believe that they are allowed to tow a loaded 2 tonne trailer (mini digger) with a 7. 5 tonne truck on a pre '97 car licence, because the  combination does not exceed 8. 25 tonnes.  

33 minutes ago, Mr Plodd said:

 

The issue of max WEIGHT doesn’t come into HGV licence types, it’s theconfiguration  of HGV that determines the licence category.  If you look on the back of your licence you will see various pictograms of the different vehicle combinations with the licence category to the left. C1 is for two axle rigids over 7500kg, C is for multi axle rigid over 7500 C1E is for rigid and trailer exceeding 7500 etc

 

Each of those categories have maximum weights that are dependant on the number of axles fitted. Two axle trucks can go up to 16 tonnes, 3 axles to 24 etc. The  general rule is 8 tonnes per axle as a rough guide ( but of course there are execeptions!) 

 

i hope that explains things?

 

Andy

 

I'm afraid I have to disagree with you Mr Plodd. I have driven a few 2 axle HGVs plated to 18 tonnes.    https://assets. publishing. service. gov. uk/government/uploads/system/uploads/attachment_data/file/211948/simplified-guide-to-lorry-types-and-weights. pdf    ;)

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9 hours ago, Simple Life said:

You clearly don't accept or have not read the link,  https://www. gov. uk/vehicle-weights-explained

 

Thanks for having not one, but two attempts at answering my points.  However you have clearly missed them both.

 

Not only did I read the link you quoted, but it is the terms of that that I was questioning.  I repeat, (3rd time).

 

The quote from your link.

 

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.”

 

My question.

 

In what circumstances could a caravan manufacturer honestly say it is UNLIKELY to be loaded beyond the random figure they choose to use.

 

Secondly.  Given that down plating is allowed in the circumstances you refer too.  There is still the matter of what info needs to be displayed and how it should be a afixed.

 

I am sorry if I have upset you.  But I have not doubted you or your link, just simply questioning it rather than accepting it on face value.

 

John

 

 

 

Edited by JCloughie

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6 minutes ago, JCloughie said:

 

Thanks for having not one, but two attempts at answering my points.  However you have clearly missed them both.

 

Not only did I read the link you quoted, but it is the terms of that that I was questioning.  I repeat, (3rd time).

 

The quote from your link.

 

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.”

 

My question.

 

In what circumstances could a caravan manufacturer honestly say it is UNLIKELY to be loaded beyond the random figure they choose to use.

 

Secondly.  Given that down plating is allowed in the circumstances you refer too.  There is still the matter of what info needs to be displayed and how it should be a afixed.

 

I am sorry if I have upset you.  But I have not doubted you or your link, just simply questioning it rather than accepting it on face value.

 

John

 

 

 

 

Towtug has explained it all quite well. Downplating is only possible if the manufacturer has provided for downplating in his type approval documentation. Otherwise, he would have to apply for an extension to the existing type approval to cover the downplated limit before he can issue a new plate.

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23 minutes ago, Flat_at said:

A driving licence tells you only what you can drive. I have had to "educate" quite a few people who believe that they are allowed to tow a loaded 2 tonne trailer (mini digger) with a 7. 5 tonne truck on a pre '97 car licence, because the  combination does not exceed 8. 25 tonnes.  

I'm afraid I have to disagree with you Mr Plodd. I have driven a few 2 axle HGVs plated to 18 tonnes.    https://assets. publishing. service. gov. uk/government/uploads/system/uploads/attachment_data/file/211948/simplified-guide-to-lorry-types-and-weights. pdf    ;)

 

Oooops!! :wub:

 

Yes sorry typo on my part, the max axle weights were increased a good few years ago,  but the principle is the same, it’s the type of configuration that dictates the licence category not the weight.  

 

Andy

 

 

 

52 minutes ago, Lutz said:

 

One should point out  that you are talking about 'Ministry plates' here which are only relevant to goods vehicles. The issue at hand is the statutory plate which is something else and applies to all vehicles, not just goods vehicles.

 

The question I was answering (now 15 posts back!!) was specific to HGV’s so I answering that question, I didn’t quote it to save a bit of space 

 

Andy

Edited by Mr Plodd

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13 minutes ago, JCloughie said:

 

Thanks for having not one, but two attempts at answering my points.  However you have clearly missed them both.

 

Not only did I read the link you quoted, but it is the terms of that that I was questioning.  I repeat, (3rd time).

 

The quote from your link.

 

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.”

 

My question.

 

In what circumstances could a caravan manufacturer honestly say it is UNLIKELY to be loaded beyond the random figure they choose to use.

 

Secondly.  Given that down plating is allowed in the circumstances you refer too.  There is still the matter of what info needs to be displayed and how it should be a afixed.

 

I am sorry if I have upset you.  But I have not doubted you or your link, just simply questioning it rather than accepting it on face value.

 

John

 

 

 

 

 

A caravan can have lower weight by reducing the payload allowance and the Vin plate is changed or a sticker is stuck over the existing sticker but if the caravan is EU type approved the weight limit would be subject to the type approval range .  

 

 

Dave

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6 minutes ago, Mr Plodd said:

 

Oooops!! :wub:

 

Yes sorry typo on my part, the max axle weights were increased a good few years ago,  but the principle is the same, it’s the type of configuration that dictates the licence category not the weight.  

 

Andy

 

 

 

It happens to us all  ;) it's our age:)

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1 hour ago, Lutz said:

 

Towtug has explained it all quite well. Downplating is only possible if the manufacturer has provided for downplating in his type approval documentation. Otherwise, he would have to apply for an extension to the existing type approval to cover the downplated limit before he can issue a new plate.

 

1 hour ago, CommanderDave said:

 

 

A caravan can have lower weight by reducing the payload allowance and the Vin plate is changed or a sticker is stuck over the existing sticker but if the caravan is EU type approved the weight limit would be subject to the type approval range .  

 

 

Dave

I was not disputing or questioning any of the above.   Just trying to get clarity on Simple Life's link.

 

John

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5 hours ago, Lutz said:

 

Who says that downplating is not a radical alteration? Surely everything that affects type approval is radical.

 

And where is reference to the exact plating requirements to be found in Part 2 of the Road Traffic Act 1988? I can only find general reference in part 2 of that act to plating requirements, but nothing specific. Maybe I have overlooked something.

 

 

Just quoting and pasting directives doesn't show any understanding. In fact you have misled this thread, for reasons I can only guess at.

 

To all who can't be bothered to look.

 

The C&U regs incorporate EU regs, but also stipulate their own criteria which UK manufacturers must by law adhere to 

 

Within it states

Manufacturers not plating the vehicle at its upper weight

 

Placing of a plate in a conspicuous position. (Sound familiar, yes caravan door)

 

What should be on the plate

 

The size of the lettering.

 

It's all there.

 

Oh and finally, the EU plate is not hidden  away. It should by EU law be placed on the bulkhead, or on a part not readily replaced, which is found? Yes in the gas locker at the front!

 

Edited by Grandpa Steve

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I find it frankly outrageous that you can suggest that Lutz has misled this discussion.  The fact that you have implied that he has done this deliberately is unforgivable.   You have made assertion after assertion, but not once have been willing to actually provide evidence despite repeated requests.  

 

 

 

 

 

 

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6 minutes ago, fred said:

I find it frankly outrageous that you can suggest that Lutz has misled this discussion.  The fact that you have implied that he has done this deliberately is unforgivable.   You have made assertion after assertion, but not once have been willing to actually provide evidence despite repeated requests.  

 

 

 

 

 

 

I have provided evidence.

 

UK CONSTRUCTION & USE Regs

 

Go look at them.  

 

PDF format, the sections are very long, I have just a moment ago provided descriptions, which you choose to ignore!

Why?

 

As for another poster insisting EU regs/posting are absolute is wrong, therefore misleading.

 

Example

UK motorhomes are allowed to use A frames, Germany not allowed.

Edited by Simple Life

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50 minutes ago, Simple Life said:

I have provided evidence.

 

UK CONSTRUCTION & USE Regs

 

Go look at them.  

 

PDF format, the sections are very long, I have just a moment ago provided descriptions, which you choose to ignore!

Why?

 

As for another poster insisting EU regs/posting are absolute is wrong, therefore misleading.

 

Example

UK motorhomes are allowed to use A frames, Germany not allowed.

 

You have not stated which amendment of the Construction and Use Regulations you are looking at. There are almost yearly amendments and I am not going to plough through them all to find the relevant passages, so please point us to the actual paragraph that has given you the information that you claim to have.

Nor have you given an answer as to where it is stated that UK Construction and Use Regulations take priority over UK Vehicle Approval Regulations.

What A-frames on motorhomes has to do with the topic at hand is a mystery to me. By the way, A-frames are not prohibited in Germany in principle, but they would require type approval as a trailer, and no manufacturer has had them type approved as a unit with the respective towed vehicle. That is why they are not allowed. They are not explicitly allowed in the UK either, but because there is no piece of legislation that covers them, they are tolerated.

 

Edited by Lutz
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59 minutes ago, Simple Life said:

I have provided evidence.

 

UK CONSTRUCTION & USE Regs

 

Go look at them.  

 

PDF format, the sections are very long, I have just a moment ago provided descriptions, which you choose to ignore!

Why?

 

As for another poster insisting EU regs/posting are absolute is wrong, therefore misleading.

 

Example

UK motorhomes are allowed to use A frames, Germany not allowed.

 

Can I respectfully point out that you have not provided ANY evidence, merely a suggestion that others go and read the C&U Regs

 

Can I also suggest that as you are clearly an expert in interpreting the Con & Use Regs   that you copy and paste the relevant section into a post? It only takes a moment (in fact quicker than typing a description of what you have read)  and then everyone else can read what exactly you keep making reference to? 

 

That surely is a much better response than your rather arrogant, “Go look at them”

 

Andy

 

Edited by Mr Plodd
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I've had a look at C&U and as far as I can see the plating requirements for a trailer are as per WVTA. The NCC sticker that's usually placed near the door of a caravan does not comply with the information required by the C&U regs.

 

Reading further it seems that C&U has occasionally been amended to bring it in line with WVTA and in a lot of cases the C&U regulation was/is identical to the WVTA .

 

As far as I can see the WVTA plate is the legally required plate and the exterior one is fitted by the manufacturer as a condition of membership of the NCC. The NCC are not a regulatory body and therefore the information on the NCC plate, unless a repetition of what's on the WVTA plate, cannot be legally binding.

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3 minutes ago, Steamdrivenandy said:

I've had a look at C&U and as far as I can see the plating requirements for a trailer are as per WVTA. The NCC sticker that's usually placed near the door of a caravan does not comply with the information required by the C&U regs.

 

Reading further it seems that C&U has occasionally been amended to bring it in line with WVTA and in a lot of cases the C&U regulation was/is identical to the WVTA .

 

As far as I can see the WVTA plate is the legally required plate and the exterior one is fitted by the manufacturer as a condition of membership of the NCC. The NCC are not a regulatory body and therefore the information on the NCC plate, unless a repetition of what's on the WVTA plate, cannot be legally binding.

:goodpost:

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49 minutes ago, Mr Plodd said:

 

Can I respectfully point out that you have not provided ANY evidence, merely a suggestion that others go and read the C&U Regs

 

Can I also suggest that as you are clearly an expert in interpreting the Con & Use Regs   that you copy and paste the relevant section into a post? It only takes a moment (in fact quicker than typing a description of what you have read)  and then everyone else can read what exactly you keep making reference to? 

 

That surely is a much better response than your rather arrogant, “Go look at them”

 

Andy

 

You CANNOT copy and paste as I have pointed out it's a PDF format. Well i cannot using my mobile. Therefore I suggested you go look at them, apology accepted.

 

It's very simple to find the relevant information within, but you must take into account exclusions/vehicle type.

 

All you have to do is follow the relevant chapter and Schedules noting vehicle type, amendments and exclusions.

 

You will find what I stated above.

Edited by Simple Life

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Well I NEVER expected this thread to generate so much interest (and controversy) 

 

Currently there have been 439 replies, and an even more amazing 10,025 views.  

 

Sadly it still hasn’t been resolved. My next move I think will be to get photographs of both plates and then contact the lead person at the Association of Chief Police Officers (ACPO) who is the lead on Road Policing and ask THEM which plate they would consider to be the one showing the max legal weight. As it’s the Police who enforce driving licence regs etc I suspect I will get a very comprehensive (and of course unambiguous) answer But that’s going to have to wait until next week now as I have a very busy weekend.

 

Many thanks to those who have taken the time and effort to do some research and post their findings on this thread. To pinch someone else line “Every little helps” 

 

One thing is clear, I am not the only one wanting a PROPER answer.

 

Andy

Just now, Simple Life said:

You CANNOT copy and paste as I have pointed out it's a PDF format. Therefore I suggested you go look at them, apology accepted.

 

It's very simple to find the relevant information within, but you must take into account exclusions/vehicle type.

 

All you have to do is follow the relevant chapter and Schedules noting vehicle type, amendments and exclusions.

 

You will find what I stated above.

 

How about a link to it then?.

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19 hours ago, Mr Plodd said:

How about a link to it then?.

I will try later, but using my mobile, but all you have to do is search and it's pretty much the first few entries

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19 minutes ago, Simple Life said:

You CANNOT copy and paste as I have pointed out it's a PDF format. Well i cannot using my mobile. Therefore I suggested you go look at them, apology accepted.

 

It's very simple to find the relevant information within, but you must take into account exclusions/vehicle type.

 

All you have to do is follow the relevant chapter and Schedules noting vehicle type, amendments and exclusions.

 

You will find what I stated above.

 

If you can't copy and paste then at least state which amendment, schedule, section, and paragraph we are supposed to have a look at. Then we can go into the legislation. co. uk website and read for ourselves. It's not in PDF format there.

Edited by Lutz

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25 minutes ago, Lutz said:

 

If you can't copy and paste then at least state which amendment, schedule, section, and paragraph we are supposed to have a look at. Then we can go into legislation. co. uk and read for ourselves. It's not in PDF format there.

The headings are straight forward 

 

Trailers

Weights

Plates

 

Leading to schedule 8

 

Part 2

 

Above from memory

 

You cannot just simply look at A chapter, it is written as a family tree, so you must follow The correct passages.

 

Mr Plodd

The answer from ACPO will be they go on the manufacturers plate,(my telly example) which you are all believing to be a NCC plate. I stated NCC REPRESENT the manufacturer 

 

Jcloughie

I cannot give an answer to why "Unlikely" Is used by caravan manufacturers, but my educated guess would be along the lines of THE payload calculation. But you asked is downplating legal, what you ask now is why they can do it, a different question 

 

I keep saying The End  this time it is.

 

You have enough information now to find the answers you require, if you can't  then carry on.

 

 

 

Edited by Simple Life

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13 minutes ago, Simple Life said:

The headings are straight forward 

 

Trailers

Weights

Plates

 

Leading to schedule 8

 

Part 2

 

From memory

 

 

 

And what is the year of the amendment? As there are about 40 to 50 amendments it would make it a lot easier to find if we knew which year.

Edited by Lutz

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C&U schedule 8 only requires what is required under EU trailer type approval plating .

 

My issue is why have maximum plated axle weights and then say they will not be checked when a TA can exceed a axle limit without exceeding it's Mtplm ?

 

 

Dave

 

 

Edited by CommanderDave

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9 minutes ago, CommanderDave said:

C&U schedule 8 only requires what is required under EU trailer type approval plating .

 

My issue is why have maximum plated axle weights and then say they will not be checked when a TA can exceed a axle limit without exceeding it's Mtplm ?

 

 

Dave

 

 

 

In other words, the Construction and Use Requirements are the same as the Vehicle Approval requirements and I have already quoted those.

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1 hour ago, Simple Life said:

Jcloughie

I cannot give an answer to why "Unlikely" Is used by caravan manufacturers, but my educated guess would be along the lines of THE payload calculation. But you asked is downplating legal, what you ask now is why they can do it, a different question 

 

To me, UNLIKELY is the word used by the manufacturer as, according to the quote from your previous link:

 

“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.”

 

It becomes the only reason they can use to downplate.

 

I agree with you that if asked to explain their reasoning they would say its to do with the payload calculation.

 

My point is.   That on most UK vans with such a tiny payload.   That would be a very hard explanation to get a court to accept.

 

At no point have I asked if downplating is legal.   Nor have I asked why they can do it.   I really do not know where you have got that from.

 

What I did ask though.   given that the link you provided is the current legal position.   (I do not have the knowledge to dispute that, so will not try).  Once the manufacturer had downplated.   can you you direct me to the part of those regs which say what that plate should contain and how is should be affixed.

 

Simple Life, I get the distinct impression you are getting irritated.   but if you read back, I have at no time suggested you are misleading or are wrong.   Just asking for clarification on a couple of points.   I feel that if you were able to prove them it may support your case

 

John

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If the requirements for labelling under C&U are identical to those under WVTA it follows that the label used by most UK caravan manufacturers in the gas locker , or in the case of Hymer UK and Lunar, on their van sides, is both C&U and WVTA compliant, serving both purposes and is the statutory plate.

 

There are still two issues that need answers:

1. Why, do manufacturers who wish to specify a lower MTPLM than the van's axle limit, not specify that lower limit on the statutory plate?

2. If a lower MTPLM is specified on the NCC plate or combined NCC and statutory plate (Hymer & Lunar) how can it be legal if it isn't displayed in the format required by both sets of regulations?

 

The second question is really the one that Andy started this whole saga off with and we still have no formal definitive answer. 

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