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Caravan gross weight, a response from Bailey!


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10 minutes ago, Lutz said:

 

The regulations are fairly clear. There's no mention in any of them of a second plate.  MTPLM is also clearly defined, so what more do you want? 

 

It would help if the regulations specified a size and specific, conspicuous location for the statutory plate "on the nearside, visible from the outside, no more than 1 metre behind the hitch". With the statutory plate clearly visible, in a standard location and conforming to the standard format any enforcement authority would be less likely to give credence to a non-statutory plate.

 

My biggest fear in all this is that the lower, arbitrary figure will become standard!

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Earlier this afternoon I had a very lengthy telephone conversation with a (caravan owning) technical chap from DVSA. He rang me!    He clearly knows his subject inside out and backwards. We

Don't forget that the same regulations also affect the road haulage and agricultural industries who, collectively, have more political power than the caravan industry! The caravan industry, altho

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25 minutes ago, Lutz said:

That's no better. How is one supposed to know which plate to look at if there are two, especially if both comply with the format required for statutory plates and both apply to the same build stage?

 

 

Maybe if the regulation required a tamperproof date of issue on the plate. Then an enforcement officer would have to use the info. on the plate with the latest date.

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14 minutes ago, fraser600 said:

Has anybody ever been stopped and had the weight checked ? It's seems that know one in authority knows or indeed cares,  

 

Yes some have.

 

If towing a rig on a B licence with plated weights above 3500kg then prosecution for driving without appropriate licence.

 

If within the driver's licence but over MTPLM then the usual procedure is to give the driver a chance to redistribute the weight, so that the MTPLM is no longer exceeded. If driver refuses, cannot redistribute and/or will not leave some weight behind, then they have to unhitch and collect van later when they can remove excess weight and may they be reported for prosecution.

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2 hours ago, Mr Plodd said:

That upgrade would come with TWO NEW plates to replace the originals, no room for any misinterpretation or confusion of any kind.  

 

Why two.  One, as with cars, would suffice.  I think from a previus post it only needs to be ‘accessable’.  Not necessarily visible from the outside, like cars.  So either location would comply.  But standardisation in the industry sounds most preferable to me.

 

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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It's difficult to prescribe the location of the plate because the regulation applies to all vehicles, whether car, trailer, lorry, bus or whatever. The environment where the plate can be placed is different in each case. It should suffice that the location is stated in the owner's handbook and the owner is in a position to show the traffic officer where it is if the officer can't readily find it himself.

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1 hour ago, Lutz said:

 

The regulations are fairly clear. There's no mention in any of them of a second plate.  MTPLM is also clearly defined, so what more do you want? It can only be a question of whether powers-that-be can make up their own rules as they see fit, just to make things easy for themselves by looking at a label by the door which isn't covered by any regulation.

 

 

That's no better. How is one supposed to know which plate to look at if there are two, especially if both comply with the format required for statutory plates and both apply to the same build stage?

 

The regulations should be patently/categorically clear.   Fairly is indecisive and that is partly why this topic has limped-on for so long.

Life in general can be a journey of chance with some winners and sadly some losers. Your outfit can never be left to chance. A short-while carrying out essential checks can ensure a long-time of happy & safe caravanning for all concerned.
Ignorance can often be bliss but is certainly not an excuse and when continually disregarded they can be totally disastrous for oneself and the innocent parties.

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11 minutes ago, AWanderingLancastrian said:

The regulations should be patently/categorically clear.   Fairly is indecisive and that is partly why this topic has limped-on for so long.

The regulation is clear.

 

Article 2 Definitions

 

Manufacturers Statutory plate means a plate or label affixed by the manufacturer . ...........necessary for the identification of a vehicle and provides the competent authorities with the relevant information concerning the permissible maximum laden masses.

 

Article 3

 

The manufacturer. ........shall submit to the type approval authority an application. ..........the layout and location of the manufacturers statutory plate. ........

 

Part A 

General provisions. ........describe exactly what the plate or label should be made of and what it should look like.

 

It says each vehicle must be fitted with THE MANUFACTURERS statutory plate. (NCC are not the manufacturer)

 

Annex ii

 

Says it must be fitted in a conspicuous and readily accessible position, and to a part that is not readily replaced in normal use .

 

All of this gets taken into UK law by the road vehicles approval regulations 2009 as amended.  

 

In the definitions used for EU regulations

The means a definitive and specific article.

They refers to a number of articles (not quantity specific) 

 

The text clearly refers to THE, meaning the Statutory plate information should only be there in one place.

 

 

 

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Hi Towtug. Yes,I am aware of of all of the speal  but is was the use of FAIRLY CLEAR that I reacted to.

In my book anything that is FAIRLY anything is not definite and or clearly defined as so much of the garbage that has come out of the EU with their directives on this,that and the other.

Life in general can be a journey of chance with some winners and sadly some losers. Your outfit can never be left to chance. A short-while carrying out essential checks can ensure a long-time of happy & safe caravanning for all concerned.
Ignorance can often be bliss but is certainly not an excuse and when continually disregarded they can be totally disastrous for oneself and the innocent parties.

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5 minutes ago, AWanderingLancastrian said:

Hi Towtug. Yes,I am aware of of all of the speal  but is was the use of FAIRLY CLEAR that I reacted to.

In my book anything that is FAIRLY anything is not definite and or clearly defined as so much of the garbage that has come out of the EU with their directives on this,that and the other.

I think we 're on the same page. However  its my view, that it's the EU regulations that are crystal clear and the UK administrations interpretation that is at fault.

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7 hours ago, Mr Plodd said:

To my very simple mind the manufacturers could (IF they had the will) sort this debacle out very easily indeed.

 

They produce the caravan with BOTH  plateS showing the lower weight limit and then offer an “upgrade” to the higher weight.  

 

That upgrade would come with TWO NEW plates to replace the originals, no room for any misinterpretation or confusion of any kind.  

 

Having upgraded a motorhome in the past I was indeed supplied with a brand new “statutory” or VIN plate showing the higher weight limit along with all the other required data, It had to be affixed NEAR TO but NOT over the original.  

 

Perhaps that’s too logical for the NCC/caravan manufacturers. Perhaps I should write to them suggesting they do just that! They might even take it onboard, Har ***** Har :o

 

Andy

They produce the caravan with BOTH  plateS showing the maximum weight limit and then offer an “downgrade” to the lower weight(specific to divers/owners requirements)

The manufacturer would then still be able to charge for replacement "decals"and a new CofC to satisfy police of  B driving licience regs conformity and then the sale of a new "decal" and CofC if on resale wished to be changed back by 2nD/3rd/4th owner

correct me if i am wrong but i dont remember reading anywhere about upgrading in the regulations only downplating

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1 minute ago, wiganian said:

They produce the caravan with BOTH  plateS showing the maximum weight limit and then offer an “downgrade” to the lower weight(specific to divers/owners requirements)

The manufacturer would then still be able to charge for replacement "decals"and a new CofC to satisfy police of  B driving licience regs conformity and then the sale of a new "decal" and CofC if on resale wished to be changed back by 2nD/3rd/4th owner

correct me if i am wrong but i dont remember reading anywhere about upgrading in the regulations only downplating

 

You most certainly can up-plate (some) motorhomes, I’ve done it.  So it’s reasonable to assume it’s possible with a caravan. In fact that exactly what Bailey do. They sell you a caravan with an external decal which shows the MTPLM that they have decided on and then offer to upgrade that to what’s on the Statutory plate (for a fee of course) 

 

Andy

Experience is an awful teacher who ends up sending you simply horrifying bills

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6 hours ago, Steamdrivenandy said:

 

Maybe if the regulation required a tamperproof date of issue on the plate. Then an enforcement officer would have to use the info. on the plate with the latest date.

My Ssangyong pickup falls into this category. initially released with a gvw of 2700kg then when Ssy realised they were losing sales and car bik allowance as it did not have a tonne payload, they upgraded the rear suspension. I have two plates inside the door and the second is clearly marked stage two with a different type approval number.

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In your motorhome up-plate did you have to make changes the required you to get a new VIN plate? 

if not then i would suggest that you just paid for a new "decal"

if so then i would suggest that it wasn't an up-plate rather aplication to change the weight limits

If as you have stated on numourous occations the caravan has a vin plate with a maximum MTPLM (all regulations included) this cannot be up-plated without new type approval

As this cannot be up-plated only down-plated it would  be a reasonable suggestion that i posted

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I had to change the rear tyres to those with a higher load rating and install air suspension assisters to the rear axle. So thinking about it I think you are correct!

 

Andy

Experience is an awful teacher who ends up sending you simply horrifying bills

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If the base vehicle at Stage 1 has a higher MAM than that shown at Stage 2 it is possible to up plate, but only if the St2 manufacturer includes the higher MAM in the St2 approval.

For example Renault Master MAM at St 1, 4250, converted to a motor home at St 2 the manufacturer plates at 3500.

 

This could be up plated but only to the figures allowed for in the St 2 approval. Generally no additional tests by the manufacturer  are required.

 

Some St2 manufacturers increase the St1 MAM during conversion by using Air assist etc. In this case they have to take responsibility for additional tests, for brakes, steering and lane change stability etc.

16 minutes ago, wiganian said:

In your motorhome up-plate did you have to make changes the required you to get a new VIN plate? 

if not then i would suggest that you just paid for a new "decal"

if so then i would suggest that it wasn't an up-plate rather aplication to change the weight limits

If as you have stated on numourous occations the caravan has a vin plate with a maximum MTPLM (all regulations included) this cannot be up-plated without new type approval

As this cannot be up-plated only down-plated it would  be a reasonable suggestion that i posted

This could be up plated if there was scope to doubt within the original type approval. What it would generally mean is that the van would become a different Variant and Version and would therefore require a different C of C.

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Subject to certain technical conditions being fulfilled, there is no limit to how much a caravan can be up-plated, even beyond what the manufacturer has had type approved. At least in Germany AlKo offer such a service. Mind you it's not cheap as it may involve replacing the whole chassis. If that is the case it will cost a minimum of €4500. They will then arrange an individual vehicle approval of the modified caravan. I don't know whether the scheme is also available in the UK.

 

7 hours ago, Steamdrivenandy said:

 

Maybe if the regulation required a tamperproof date of issue on the plate. Then an enforcement officer would have to use the info. on the plate with the latest date.

 

I can't see the point of having to retain the old statutory plate. I think someone has got things wrong somewhere to demand it. I don't know of any such requirement documented anywhere.

 

Edited by Lutz
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17 hours ago, Towtug said:

The regulation is clear.

 

Article 2 Definitions

 

Manufacturers Statutory plate means a plate or label affixed by the manufacturer . ...........necessary for the identification of a vehicle and provides the competent authorities with the relevant information concerning the permissible maximum laden masses.

 

Article 3

 

The manufacturer. ........shall submit to the type approval authority an application. ..........the layout and location of the manufacturers statutory plate. ........

 

Part A 

General provisions. ........describe exactly what the plate or label should be made of and what it should look like.

 

It says each vehicle must be fitted with THE MANUFACTURERS statutory plate. (NCC are not the manufacturer)

 

Annex ii

 

Says it must be fitted in a conspicuous and readily accessible position, and to a part that is not readily replaced in normal use .

 

All of this gets taken into UK law by the road vehicles approval regulations 2009 as amended.  

 

In the definitions used for EU regulations

The means a definitive and specific article.

They refers to a number of articles (not quantity specific) 

 

The text clearly refers to THE, meaning the Statutory plate information should only be there in one place.

 

 

 

The above may be correct and apply to trailers over 2300kg however does the plate on a caravan conform to statutory requirements as it does not have a VIN or ID number?  BTW can you please post a link to the above so that I can have a read?  Thanks

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52 minutes ago, Durbanite said:

The above may be correct and apply to trailers over 2300kg however does the plate on a caravan conform to statutory requirements as it does not have a VIN or ID number?  BTW can you please post a link to the above so that I can have a read?  Thanks

 

With the introduction of whole vehicle type approval for all trailers whatever the weight, they must all have a VIN. There is no exception for those under 2300kg. By the way, where did you get that 2300kg breakpoint from?

 

Edited by Lutz
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3 hours ago, Durbanite said:

The above may be correct and apply to trailers over 2300kg however does the plate on a caravan conform to statutory requirements as it does not have a VIN or ID number?  BTW can you please post a link to the above so that I can have a read?  Thanks

DB

We've been through the VIN bit several times on this thread. Caravan makers all allocate a VIN to their vans on the production line. The VIN is stated on the mandatory plate and CRiS use the VIN number to register the vans on their system. I believe Lutz also asked where you got the 2300kg limit from earlier too, but he never got an answer. 

I've got nothing to do on this hot afternoon

but to settle down and write you a line.

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22 hours ago, Lutz said:

It's difficult to prescribe the location of the plate because the regulation applies to all vehicles, whether car, trailer, lorry, bus or whatever. The environment where the plate can be placed is different in each case. It should suffice that the location is stated in the owner's handbook and the owner is in a position to show the traffic officer where it is if the officer can't readily find it himself.

 

 

The owner has responsibility to have checked the plated weights that he complies to all the regulations on the road so he will know or has found out the location of the plates on a car and caravan ?

 

 

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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4 hours ago, Lutz said:

 

With the introduction of whole vehicle type approval for all trailers whatever the weight, they must all have a VIN. There is no exception for those under 2300kg. By the way, where did you get that 2300kg breakpoint from?

 

 

 

As said all trailers come under the same umbrella .

https://www. gov. uk/government/publications/iva-manual-for-categories-01-02-03-and-04-trailers

 

All information on plating for all trailers for type  approval can be found in the trailer type approval manual .

 

 

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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4 hours ago, Lutz said:

 

With the introduction of whole vehicle type approval for all trailers whatever the weight, they must all have a VIN. There is no exception for those under 2300kg. By the way, where did you get that 2300kg breakpoint from?

 

Look it up in the legislation concerning trailers and caravans.   Over 2300kg it may not be regarded as a normal caravan.

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Which legislation is that DB?

 

And if a caravan over 2300kg isn't a 'normal' caravan, what type of caravan is it?  Subnormal? Supra- normal? Big?  Largish? Heavy?  

I've got nothing to do on this hot afternoon

but to settle down and write you a line.

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