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Caravan gross weight, a response from Bailey!


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To my knowledge, the certificate that is issued with an "upgrade" is a certificate of conformity to certain industrial standards, as required by the NCC, and not a revised type approval certificate of conformity.

Regardless of any plates on the vehicle, whether statutory or otherwise, it must be the type approval certificate of conformity that is the definitive document. and it must be what ultimately counts in the event of conflict.

 

Edited by Lutz
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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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56 minutes ago, Steamdrivenandy said:

I guess it might come back to the C of C.

 

If the weight limit shown on the certificate agrees with the exterior  NCC plate then you're banged to rights as they say 'cos there's a formal piece of paper and a plate saying the same MTPLM. However if the C of C agrees with the mandatory plate in the gas locker then only that can legally be the maximum.  

 

So, do Bailey issue a new C of C with an upgrade of weight or do they just issue a new decal? It has to be a proper legal C of C, not the pretend NCC one, which just says the van complies with NCC (i. e. the industry trade body) regulations.

 

I upgraded my current Bailey Olympus when I bought it (used) 

I was supplied with a new external decal AND a new C of C that showed the same MTPLM as the new decal. It’s a fairly comprehensive document over 4 pages of A4!

 

The previous C of C (which I still have) shows the (lower) MTPLM that was on the original external decal.

 

Andy

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

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14 hours ago, Mr Plodd said:

Looks like I will have to stump up some dosh to get my new toy “uprated” I still feel it’s a big con job by the manufacturers, but I now accept that whilst it may be unethical it’s within the current rules. Buzzer! (Can’t use G’s :excl:

 

Andy 

:Thankyou:

 

Why would you want to pay when all you have to do is remove the sticker with the lower MTPLM on the outside of the caravan.   Perfectly legal according to your post above.

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9 minutes ago, Mr Plodd said:

 

I upgraded my current Bailey Olympus when I bought it (used) 

I was supplied with a new external decal AND a new C of C that showed the same MTPLM as the new decal. It’s a fairly comprehensive document over 4 pages of A4!

 

The previous C of C (which I still have) shows the (lower) MTPLM that was on the original external decal.

 

Andy

 

Just out of interest, does the revised certificate carry the type approval number and the name of the type approval authority that carried out the approval?

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36 minutes ago, Lutz said:

 

Just out of interest, does the revised certificate carry the type approval number and the name of the type approval authority that carried out the approval?

 

I will check later and let you know! I suspect the type approval will be the same. Both certificates appear to be identical EXCEPT for the MTPLM. (I will try and scan the respective part of both) It will not affect the fact that it’s the CofC that’s the final point of reference.

 

As I posted earlier there are HGV’s on the road that have a type approval weight of 8000 Kg and that’s what is shown on the Statutory (VIN) plate BUT are (ministry) plated at 7490Kg to negate the need for the driver to hold an HGV licence. The vehicles are IDENTICAL except for the plated (NOT the type approved)  MGVW. Caravans don’t have a “Ministry” plate, but there is no legal requirement for one, but they DO have a second manufacturer’s plate.

 

I  have no doubt whatsoever that if this practice was against the law the DVSA would have jumped on it many years ago. They haven’t and it’s a fairly common practice, and certainly one I was made aware of very early on in my career as a traffic cop.

 

Having had this lengthy chat over the finer points of the regs (which you do need a fair bit of knowledge to interpret) I am happy with the explanation I received.

 

Others are welcome to have their own views, however how many of them have had 30 years experience of having to interpret and enforce them as I have. ?  ( or spoken at length and in detail, with a clear expert from DVSA) 

 

Andy

 

 

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

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The reason why I asked was only to establish for sure whether the certificate that you have received is a true type approval certificate because I have seen certificates of conformity for caravans that only certify meeting certain industry standards and they would only be intended as information for the owner, but have no significance for any traffic officer.

 

The so-called Ministry plate would also only be valid within the UK as there is nothing equivalent abroad. The driver would not be able to lay claim to any MTPLM on that when abroad to get by with a lower driving licence category.

 

Once again, the second plate is specific to most but not all UK caravans and certainly not to all trailers and there are no provisions in any legislation for it, so any authority that it may carry must remain questionable, regardless of what the DVSA or anyone else says.

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I can't see why you can't just remove the side sticker if you want to use the higher value on the statutory plate in the locker as my new car trailer only has the one statutory plate which would be used by authorities so why would it make any difference on a caravan that is only a trailer in law ?

 

Why would you need to pay out .

 

 

 

 

 

 

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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9 minutes ago, CommanderDave said:

I can't see why you can't just remove the side sticker if you want to use the higher value on the statutory plate in the locker as my new car trailer only has the one statutory plate which would be used by authorities so why would it make any difference on a caravan that is only a trailer in law ?

 

Why would you need to pay out .

 

Dave

 

That only solves the problem for someone who wants his caravan 'uplated', but it's of no help in the case where the MTPLM on the second plate is lower than on the statutory plate and one relies on that lower value for driving licence entitlement purposes.

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14 minutes ago, Lutz said:

 

That only solves the problem for someone who wants his caravan 'uplated', but it's of no help in the case where the MTPLM on the second plate is lower than on the statutory plate and one relies on that lower value for driving licence entitlement purposes.

 

 

I agree I can't see where this second plate fits in law only to add a loading value or working value and I don't think you could compare the two with a goods vehicle plated with registration Ministry plates ?

 

The ministry plate is the same as replating and would supersede the manufacturers plating or previous plating .

 

Downplating of  trailers was based on revenue weight when a trailer could be downloaded if not used to its capacity to save money for a haulage company .

 

 

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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Just checked both C of C’s (on stiff card not paper) Same Type Approval number, same caravan VIN number, the only differences being the MTPLM  and payload.  They are on two sides of an A4 not 4 

 

The C of C appears to be issued by the NCC in conjunction with Bailey. (Large NCC logo)

Now that could be argued as not being an “official” document, but I am not aware of any “official” body that actually ISSUES  C of C’s or VIN plates.

Take the car industry for example, I don’t think it’s even possible for an “official” body to issue each and every car with its own individual VIN plate/sticker, it’s simply not feasible due to the sheer volume of cars that are produced each and every day.  Therefore responsibility must be derogated to the manufacturer, which is what the caravan industry doing.

 

Though it grieves me I am coming to the conclusion that I have exhausted this enquiry. It MAY be that the whole subject needs reviewing/altering/improving but I certainly do not have the skills, time or most importantly the money to do that. Therefore I/we have little option other than to (reluctantly) accept the situation (as unsatisfactory as it seems) and get on with things.  

 

If anyone else wishes to take up the cudgel then please feel free to use any of the information I have garnered, but I am not going to pusue it any more, I have given it my best and I am pretty happy that what the industry are doing complies with what the DVSA say and, right or wrong, it’s them who any court will almost certainly take their lead from!

 

Andy

9 minutes ago, CommanderDave said:

 

 

I agree I can't see where this second plate fits in law only to add a loading value or working value and I don't think you could compare the two with a goods vehicle plated with registration Ministry plates ?

 

The ministry plate is the same as replating and would supersede the manufacturers plating or previous plating .

 

Downplating of  trailers was based on revenue weight when a trailer could be downloaded if not used to its capacity to save money for a haulage company .

 

 

Dave 

 

Dave

 

If you wish to continue this crusade then please do, (see above) for me, to quote Dragons Den “I’m out” 

 

Andy

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

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I think it is at the top again and as said " smoke and mirrors "?

 

 

 

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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22 hours ago, Durbanite said:

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

 

You'll have to do better than that!   :rolleyes: 

 

To what legislation are you referring?

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1 hour ago, Mr Plodd said:

Just checked both C of C’s (on stiff card not paper) Same Type Approval number, same caravan VIN number, the only differences being the MTPLM  and payload.  They are on two sides of an A4 not 4 

 

The C of C appears to be issued by the NCC in conjunction with Bailey. (Large NCC logo)

Now that could be argued as not being an “official” document, but I am not aware of any “official” body that actually ISSUES  C of C’s or VIN plates.

Take the car industry for example, I don’t think it’s even possible for an “official” body to issue each and every car with its own individual VIN plate/sticker, it’s simply not feasible due to the sheer volume of cars that are produced each and every day.  Therefore responsibility must be derogated to the manufacturer, which is what the caravan industry doing.

 

 

Just as I thought. The CoC that you have received does not appear to be an official document relating to type approval. Such a document must be issued by the manufacturer only and carry the signature of whoever in their organisation is the person responsible. It cannot therefore bear an NCC logo. I suspect that it only certifies compliance with items such as EN1645-1, EN1645-2, EN1648-1, EN1949, EN721, but all those are industry standards only. They are not relevant to type approval.

Just as an example to check the authenticity of a proper type approval certificate of conformity it must state all pertinent dimensions, all weights, including max. axle loads, approved tyre sizes, max. allowable speed of the vehicle, etc.

 

Edited by Lutz
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3 hours ago, Mr Plodd said:

 

I will check later and let you know! I suspect the type approval will be the same. Both certificates appear to be identical EXCEPT for the MTPLM. (I will try and scan the respective part of both) It will not affect the fact that it’s the CofC that’s the final point of reference.

 

As I posted earlier there are HGV’s on the road that have a type approval weight of 8000 Kg and that’s what is shown on the Statutory (VIN) plate BUT are (ministry) plated at 7490Kg to negate the need for the driver to hold an HGV licence. The vehicles are IDENTICAL except for the plated (NOT the type approved)  MGVW. Caravans don’t have a “Ministry” plate, but there is no legal requirement for one, but they DO have a second manufacturer’s plate.

 

I  have no doubt whatsoever that if this practice was against the law the DVSA would have jumped on it many years ago. They haven’t and it’s a fairly common practice, and certainly one I was made aware of very early on in my career as a traffic cop.

 

Having had this lengthy chat over the finer points of the regs (which you do need a fair bit of knowledge to interpret) I am happy with the explanation I received.

 

Others are welcome to have their own views, however how many of them have had 30 years experience of having to interpret and enforce them as I have. ?  ( or spoken at length and in detail, with a clear expert from DVSA) 

 

Andy

 

 

 Is the definitive answer somewhere in the thread? 

I certainly have no intention of wading through 34 pages of interpretations to locate it.

I'm sure, as you say, you are satisfied with the answer to the point made in post 1.   It would be useful if that was made available as the LAST post to this thread!  

 

Santa Fe 7 Seater Premium Manual towing Swift Eccles 480 plated to 1500 kg. 

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1 hour ago, John_b_45 said:

 Is the definitive answer somewhere in the thread? 

 

 

The short answer is "No"!

The best we have is the recent conversation that Andy had with the man from DVSA, which seems to give priority to the NCC plate.

It remains to be seen whether a UK court would uphold a conviction in the case of a prosecution being based on either plate if the outfit was legal based on the other, or even if a prosecution would be sought.

Likewise a prosecution in any other country.

The only totally safe thing to do is load in accordance with the lower of the two but have a licence allowing for the higher of the two. Paying for the possibly unnecessary paper exercise if it helps.

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2 hours ago, Lutz said:

 

Just as I thought. The CoC that you have received does not appear to be an official document relating to type approval. Such a document must be issued by the manufacturer only and carry the signature of whoever in their organisation is the person responsible. It cannot therefore bear an NCC logo. I suspect that it only certifies compliance with items such as EN1645-1, EN1645-2, EN1648-1, EN1949, EN721, but all those are industry standards only. They are not relevant to type approval.

Just as an example to check the authenticity of a proper type approval certificate of conformity it must state all pertinent dimensions, all weights, including max. axle loads, approved tyre sizes, max. allowable speed of the vehicle, etc.

 

 

A copy of a proper CofC from a Swift caravan was posted on this thread a couple of pages back. The NCC headed version is not a legally approved CofC which is issued by the manufacturer under the auspices of whichever certifying authority they use. The NCC is not an authorised certifying authority.

I've got nothing to do on this hot afternoon

but to settle down and write you a line.

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Just looking on the prima parts site, at plate upgrade, and noticed this, Legal Towing 
By purchasing this weight plate upgrade certificate, you confirm that you have a suitable towcar and your driving licence allows you to tow this caravan at its MTPML Upper Limit,.  Thoughts there's only mtpml, so bailey are saying there's a lower and upper mtpml?

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At the end of the day it seems that :

  • there appears to be no law that sets out any rules about allowing manufacturer's to stipulate a lower limit than is on the mandatory plate and formal C of C. It appears to be 'custom & practice' for this to occur for the convenience of operators, allowing them to avoid restrictions on licencing regulations.
  • it is illogical to convict someone for overloading a caravan when it is within the weight limit on the mandatory plate, as there's a possibility that the plate showing any lower limit may be missing.
  • by the same token, if there was a conviction for such overloading there would be a reverse argument that any 'B' licence holder driving a rig where the mandatory plate MTPLM means the gross weights add up to more than 3500kg should also be prosecuted. 
  • overall it's a mess and the authorities should apply the law as written and not be seen to bend the rules so that they benefit the commercial interests of the caravan industry.   
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but to settle down and write you a line.

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  • 4 weeks later...

Did we ever hear where the 2300kg figure came from.

I only ask because I'm currently doing a job for an Aussie  and one of their requirements is for a mass of 2300kg for 50mm balls.

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19 hours ago, Towtug said:

Did we ever hear where the 2300kg figure came from.

I only ask because I'm currently doing a job for an Aussie  and one of their requirements is for a mass of 2300kg for 50mm balls.

 

Aren't 50mm balls rated at 3500kg so why the 2300kg figure?

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17 minutes ago, beejay said:

 

Aren't 50mm balls rated at 3500kg so why the 2300kg figure?

Specific requirement for this type of trailer in Australia.

Never heard of it in the UK.  

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  • 2 weeks later...

I previously posted on another thread (now closed) around the confusion between weights on the plate at the side of the habitation door and inside the gas locker.  In response to my original post Grandpa Steve kindly pointed me to this thread, this and various other threads around low user payload margins I thought that the Bailey response I received from Bailey may be of interest.

 

My original post in brief

Habitation door sticker MTPLM = 1682kg (this plate does NOT quote individual axle weights or the VIN) it does quote a type approval number and this is the same as the type approval number in the gas locker.

Plate in gas locker = 1800kg (this plate carries individual axle weights, type approval number & VIN)

 

I queried this with Bailey, their response quoted below.

 

"I am pleased to advise that the gas locker decal is a legal requirement whose information is helpful to the authorities if you are ever pulled over as this shows the maximum weight the fitted axle is rated to take which in this instance is 1800kg. As there is an appreciable differential between the standard MTPLM (or lower level MTPLM) and the higher level MTPLM it is possible to purchase a ‘max upgrade kit’ through our parts team (Prima Leisure) to increase the existing MTPLM of your Unicorn IV Cartagena caravan from 1682kg to 1800kg and thereby effectively increase your existing user payload from 160kg to 278kg and you may order this option via this link to the Prima Leisure website"

 

160kg as a user payload is tight and I've been weighing everything that goes in to stay within the 1682kg as I consider this prudent given my current tow car although legally I'm OK to tow up to 1900kg with my car and driving licence ... The next car may be bigger/heavier I may get the upgrade in the future but its good to be aware of the different weight plates.

 

 

Edited by TenStar
added extra comment.

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