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Mr Plodd

Caravan gross weight, a response from Bailey!

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6 minutes ago, Steamdrivenandy said:

For the present the UK is part of the EU market and because that is a single market the EU regulations have been adopted into UK law, hence the marriage between WVTA and C&U plating requirements.

 

Reducing the MTPLM at initial sale doesn't happen after the sale, so that's a red herring.

 

Before sale the standard van will have an arbitrary second MTPLM applied to it by the manufacturer. The decal that features that amended MTPLM on doesn't comply with WVTA/C&U regulations, so therefore can't be a legally enforced.   To me the answer is to have the lower weight on the statutory plate as well, so the two match, if they insist they want two plates. Why they don't put the lower weight on the statutory plate I can't figure.

 

This is not the case I’m afraid. If you go an source a car say for the German market and try and register it over here using the coc you will come unstuck.  

 

Apart from the the steering wheel being on the wrong side, the fog light may be on the wrong side, the headlights will be wrong and it won’t have mph on the speedo. It therefore won’t meet C&U.

 

You would need to therefore go through the import procedure and make alterations.  

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21 minutes ago, Steamdrivenandy said:

For the present the UK is part of the EU market and because that is a single market the EU regulations have been adopted into UK law, hence the marriage between WVTA and C&U plating requirements.

 

Reducing the MTPLM at initial sale doesn't happen after the sale, so that's a red herring.

 

Before sale the standard van will have an arbitrary second MTPLM applied to it by the manufacturer. The decal that features that amended MTPLM on doesn't comply with WVTA/C&U regulations, so therefore can't be a legally enforced.   To me the answer is to have the lower weight on the statutory plate as well, so the two match, if they insist they want two plates. Why they don't put the lower weight on the statutory plate I can't figure.

 

Why can't the caravan be sold with the offer of choice if weights at the point of sale and order free of charge like motor homes and come with the selected weight on the Vin plate . A motorhome will have a range under type approval for chassis the manufacture will then offer a choice and common is the 3850 kg-3650 and 3500 kg range for average size motorhome . If a owner then wants to upgrade to a higher weight it then given a new Vin plate .

 

So why can't it be the same they just plate to customers choice free instead of trying to squeeze money out of owners and causing plating issues .

 

 

Dave

Edited by CommanderDave

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25 minutes ago, CommanderDave said:

 

So why can't it be the same they just plate to customers choice free instead of trying to squeeze money out of owners and causing plating issues .

 

 

Dave

 

Cost of administration.

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28 minutes ago, oldboy said:

Cost of administration.

 

Why ? Sell it at the high value instead of selling  it at the lower then add the cost if you want to upgrade then there is no added cost just putting a different figure .  

 

Why would you pay when you can just pull the sticker off the side ?

 

 

Dave

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Generally an 'upgrade' is free on a new caravan if ordered upgraded. Some dealers will try and levy a charge, even though the manufacturer hasn't charged them, which is very opportunistic and smacks of exploitation, so maybe not a good dealer to buy from. 

 

Upgrading a van once it's sold, if it needs a new plate/decal, new CofC and an amendment to the manufacturer's records obviously does involve a cost and I'd say a manufacturer is entitled to earn a bob or two on that. However if the legally enforceable MTPLM is the one on the statutory plate then in buying an upgrade you are, in effect, paying for nothing as the van is already plated to the higher weight.

 

In addition, of course, there's the whole 'B' licence issue that is clouded by this plating issue too.

 

1 hour ago, handyandy said:

 

This is not the case I’m afraid. If you go an source a car say for the German market and try and register it over here using the coc you will come unstuck.  

 

Apart from the the steering wheel being on the wrong side, the fog light may be on the wrong side, the headlights will be wrong and it won’t have mph on the speedo. It therefore won’t meet C&U.

 

You would need to therefore go through the import procedure and make alterations.  

 

Source a caravan in Germany that was built for German use and you'll have to swap the wiring and lenses over for the reversing and high density fog light. You might want to swap the internal mains electric sockets to UK pattern and maybe the  gas cylinder connections but that's about it. The CofC and plating remain valid. 

 

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5 minutes ago, Steamdrivenandy said:

Generally an 'upgrade' is free on a new caravan if ordered upgraded. Some dealers will try and levy a charge, even though the manufacturer hasn't charged them, which is very opportunistic and smacks of exploitation, so maybe not a good dealer to buy from.  

 

Upgrading a van once it's sold, if it needs a new plate/decal, new CofC and an amendment to the manufacturer's records obviously does involve a cost and I'd say a manufacturer is entitled to earn a bob or two on that. However if the legally enforceable MTPLM is the one on the statutory plate then in buying an upgrade you are, in effect, paying for nothing as the van is already plated to the higher weight.

 

In addition, of course, there's the whole 'B' licence issue that is clouded by this plating issue too.

 

 

Source a caravan in Germany that was built for German use and you'll have to swap the wiring and lenses over for the reversing and high density fog light. You might want to swap the internal mains electric sockets to UK pattern and maybe the  gas cylinder connections but that's about it. The CofC and plating remain valid.  

 

 

 

But why would you need a new Vin plate when the manufacturer has made his legal obligation of declaring a maximum weight on the VIN plate .   

 

Driving licences regulations are taken on maximum plated weights on a VIN plate . I can t see how it can be legal another plate while the maximum weight is still a higher value ?

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5 minutes ago, CommanderDave said:

 

 

But why would you need a new Vin plate when the manufacturer has made his legal obligation of declaring a maximum weight on the VIN plate .   

 

Driving licences regulations are taken on maximum plated weights on a VIN plate . I can t see how it can be legal another plate while the maximum weight is still a higher value ?

 

I agree.

 

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1 hour ago, handyandy said:

 

This is not the case I’m afraid. If you go an source a car say for the German market and try and register it over here using the coc you will come unstuck.  

 

Apart from the the steering wheel being on the wrong side, the fog light may be on the wrong side, the headlights will be wrong and it won’t have mph on the speedo. It therefore won’t meet C&U.

 

You would need to therefore go through the import procedure and make alterations.  

 

Speedo showing kph is a simple if it does not show mph by wiring in a" converter" . I have done that myself on imports .

Headlights only need not cause blinding to other vehicles .

 

Fog lights can usually be swapped with rev lights on most vehicle or moved to the middle .

 

Dave

Edited by CommanderDave

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24 minutes ago, Steamdrivenandy said:

Generally an 'upgrade' is free on a new caravan if ordered upgraded. Some dealers will try and levy a charge, even though the manufacturer hasn't charged them, which is very opportunistic and smacks of exploitation, so maybe not a good dealer to buy from.  

 

I asked for an upgrade and my dealer said that he thought he could get Lunar to do it for free.   But Lunar charged £35.   Agreed the dealer may have been lying to my, but I don't think so.

 

John

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38 minutes ago, CommanderDave said:

 

Why ? Sell it at the high value instead of selling  it at the lower then add the cost if you want to upgrade then there is no added cost just putting a different figure .  

 

Why would you pay when you can just pull the sticker off the side ?

 

 

Dave

Then you will have to make your own sticker to replace the one you pull off. :D

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1 hour ago, JCloughie said:

 

I asked for an upgrade and my dealer said that he thought he could get Lunar to do it for free.   But Lunar charged £35.   Agreed the dealer may have been lying to my, but I don't think so.

 

John

 

Did you see what you got for you £35 John?

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My upgrade cost £60, I got a new plate and 100kg of payload B)

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Back home, a few quid lighter.

 

Basics.

In the UK regarding caravans and the wider field there is only one absolute legislation, The Construction & Use Regulations.

When an EU directive comes into force it is adopted into the C&U regs and the C&U regs duly amended. Not all of the regulations within the C&U have been replaced. Therefore there are still some UK regulations.

Amongst EU member states the C&U is acknowledge.

 

Caravan plates.

The NCC plate should be refered to as a manufacturers plate.

The manufacturer has to put this plate on a caravan in a conspicuous position on  a part not readily replaced.

The manufacturers plate can have the EU Approval   OR   caravan model, and a set of figures as defined in C&U regs dependent upon choice.

The manufacturer as per C&U regs can stipulate a lower weight MTPLM from the upper weight limit, some criteria are suggested other than "Unlikely".

 

The manufacturer is following the C&U regs which require the manufacturer to have the caravan type approved and affix a manufacturers plate.

 

I would suggest if the type approval plate is incorporated in the manufacturers plate there will be no plate in the front locker, where as if the other option is chosen there will be a second plate.

 

If you download a copy of the C&U regs in pdf format you can not only see EU directives adopted, hence all the amendments, but regulations regarding my post.

 

I doubt very much if I added screenshots of the regs they would help the cynical, as you need to refer back and fourth within the regs. But the "Basics" as above are that simple. If you look now with this information at various caravan plates you can see why!

 

Attached is a picture of my manufacturers plate where Coachman have elected to use the model. Note this is the upgrade plate 

 

 

 

 

 

 

20181202_131630.jpg

Edited by Simple Life
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3 hours ago, oldboy said:

Then you will have to make your own sticker to replace the one you pull off. :D

 

Why when the Vin plate in the locker meets the legal requirement under EU type approval and the RTA .

 

Dave

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35 minutes ago, CommanderDave said:

Why when the Vin plate in the locker meets the legal requirement under EU type approval and the RTA .

 

Dave

It is not.

The caravan has been approved under C&U, which is one regulation met, but not the other.

 

Example.

If you are prosecuted for an overload offence, you will not be charged with being in breach of the EU, but in breach of UK Construction and Use regulations,

 

That is because the EU directive has been adopted into our UK C&U.

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27 minutes ago, Simple Life said:

It is not.

The caravan has been approved under C&U, which is one regulation met, but not the other.

 

Example.

If you are prosecuted for an overload offence, you will not be charged with being in breach of the EU, but in breach of UK Construction and Use regulations,

 

 

 

If your prosecuted overweight it is against a plated weight which is used as evidence on the Vin plate .

 

We have already know the EU type approval regulations on plating and the mirrored requirement under the RTA  schedule 8.

 

Dave

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46 minutes ago, CommanderDave said:

Why when the Vin plate in the locker meets the legal requirement under EU type approval and the RTA .

 

Dave

You will have to consult a legal adviser who is familiar with the laws about Rules and regulations

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35 minutes ago, Simple Life said:

It is not.

The caravan has been approved under C&U, which is one regulation met, but not the other.

 

Example.

If you are prosecuted for an overload offence, you will not be charged with being in breach of the EU, but in breach of UK Construction and Use regulations,

 

That is because the EU directive has been adopted into our UK C&U.

 

In  the interests of clarity, is what you are posting an opinion, or is it based on any form of professional knowledge or qualification. 

 

I only ask in that you are very persistent in your convictions (as are those that disagree with you), and if you did have specific professional insight it might help for you to share it to help clear things up.

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13 minutes ago, CommanderDave said:

 

If your prosecuted overweight it is against a plated weight which is used as evidence on the Vin plate .

 

We have already know the EU type approval regulations on plating and the mirrored requirement under the RTA  schedule 8.

 

Dave

No.

 

You are failing to understand how regulations are incorporated.

 

Attached is a screen shot from Patterson Law containing the list of legislation breached. Within Construction and Use.

 

I have circle it for your convenience

 

 

20181202_170801.jpg

Edited by Simple Life

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2 hours ago, handyandy said:

 

Did you see what you got for you £35 John?

 

  • A nice plate by the door, see picture posted earlier.  
  • No other plate to confuse.  (Mine was a factory fit’ don’t know what Lunar would have done if I hadn’t requested the upgrade).
  • A tiny bit more confidence that I might not overload.

I have not tried, but I suspect the stick on plate would come off fairly easily.

 

Though I wholly agree with others that it’s a money making scheme.

 

John

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But as already stated to prosecute under C&U it needs a plated weight against a weighbridge ticket of the actuals . The issue is the plating regulations and when we are told the police will only use the plate on the side and when the plate on the side does not meet the road traffic act which requires manufacturer, type approval number, trailer ID number,gross weight, axle weights .

 

 

 

 

Dave

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29 minutes ago, Grandpa Steve said:

 

In  the interests of clarity, is what you are posting an opinion, or is it based on any form of professional knowledge or qualification.  

 

I only ask in that you are very persistent in your convictions (as are those that disagree with you), and if you did have specific professional insight it might help for you to share it to help clear things up.

I may be wrong I think you will find that most of the posters are only expressing an opinion according to what they are reading on the rules and regulations.

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1 hour ago, Simple Life said:

Back home, a few quid lighter.

 

Basics.

In the UK regarding caravans and the wider field there is only one absolute legislation, The Construction & Use Regulations.

When an EU directive comes into force it is adopted into the C&U regs and the C&U regs duly amended. Not all of the regulations within the C&U have been replaced. Therefore there are still some UK regulations.

Amongst EU member states the C&U is acknowledge.

 

Caravan plates.

The NCC plate should be refered to as a manufacturers plate.

The manufacturer has to put this plate on a caravan in a conspicuous position on  a part not readily replaced.

The manufacturers plate can have the EU Approval   OR   caravan model, and a set of figures as defined in C&U regs dependent upon choice.

The manufacturer as per C&U regs can stipulate a lower weight MTPLM from the upper weight limit, some criteria are suggested other than "Unlikely".

 

The manufacturer is following the C&U regs which require the manufacturer to have the caravan type approved and affix a manufacturers plate.

 

I would suggest if the type approval plate is incorporated in the manufacturers plate there will be no plate in the front locker, where as if the other option is chosen there will be a second plate.

 

If you download a copy of the C&U regs in pdf format you can not only see EU directives adopted, hence all the amendments, but regulations regarding my post.

 

I doubt very much if I added screenshots of the regs they would help the cynical, as you need to refer back and fourth within the regs. But the "Basics" as above are that simple. If you look now with this information at various caravan plates you can see why!

 

Attached is a picture of my manufacturers plate where Coachman have elected to use the model. Note this is the upgrade plate 

 

 

 

 

 

 

20181202_131630.jpg

 

I don't know why you go on about Construction and Use Regulations as if they are the only ones that apply.   Vehicle Approval Regulations are just as valid, at least on those vehicles that are subject to type approval.

You say the NCC plate should be referred to as the manufacturer's plate. Well it isn't. Legislation, even Construction and Use Regulations 1986 (Schedule 2 item 19), Talk about a statutory plate, not a manufacturer's plate and the requirements for statutory plates are clearly defined. For example, the statutory plate MUST display the type approval number if the vehicle is subject to type approval.

The photo accompanying your reply shows a label that does not display a type approval number, nor maximum axle loads, nor the maximum permissible noseweight. It therefore does not fulfil the requirements for a statutory plate. It is therefore superfluous.

 

13 minutes ago, oldboy said:

I may be wrong I think you will find that most of the posters are only expressing an opinion according to what they are reading on the rules and regulations.

 

The rules and regulations are fairly clear and precise. There is little room for personal interpretation.

1 hour ago, Simple Life said:

It is not.

The caravan has been approved under C&U, which is one regulation met, but not the other.

 

 

A caravan is not approved under C&U regulations. It is approved under Vehicle Approval Regulations.

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38 minutes ago, CommanderDave said:

But as already stated to prosecute under C&U it needs a plated weight against a weighbridge ticket of the actuals . The issue is the plating regulations and when we are told the police will only use the plate on the side and when the plate on the side does not meet the road traffic act which requires manufacturer, type approval number, trailer ID number,gross weight, axle weights .

 

 

 

 

Dave

From one persistent poster to another, the RTA refers to the  C&U on such matters, if you look into them then you will see this to be true. Good luck.

 

17 minutes ago, Lutz said:

 

I don't know why you go on about Construction and Use Regulations as if they are the only ones that apply.   Vehicle Approval Regulations are just as valid, at least on those vehicles that are subject to type approval.

You say the NCC plate should be referred to as the manufacturer's plate. Well it isn't. Legislation, even Construction and Use Regulations 1986 (Schedule 2 item 19), Talk about a statutory plate, not a manufacturer's plate and the requirements for statutory plates are clearly defined. For example, the statutory plate MUST display the type approval number if the vehicle is subject to type approval.

The photo accompanying your reply shows a label that does not display a type approval number, nor maximum axle loads, nor the maximum permissible noseweight. It therefore does not fulfil the requirements for a statutory plate. It is therefore superfluous.

 

 

The rules and regulations are fairly clear and precise. There is little room for personal interpretation.

 

You are wrong.

 

Find attached a screenshot of C&U regs regarding to manufacturers plate requirements, note OR

 

If you then look at the plate I provided you will see it is 110% compliant, the other c&U requirement is on the bulkhead in front locker.

 

Also if you now look at Bailey's response you will understand it.

Screenshot_20181202-175852_Gallery.jpg

Edited by Simple Life
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20 minutes ago, oldboy said:

I may be wrong I think you will find that most of the posters are only expressing an opinion according to what they are reading on the rules and regulations.

 

We have a lot of knowledgeable people on the forum, some work within or on the fringes of the industry, some contribute without wishing to disclose their profession. 

 As Simple Life ws very confident and persistent in what he was posting it, it came across as if he had an inside track so my question was to try to establish if he had. 

However his decision to “step aside” is indicative that his posts are his opinion and interpretation and not professional input.

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