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Mr Plodd

Caravan gross weight, a response from Bailey!

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9 hours ago, DaveMiller said:

I've just received my upgrade documents for our 2012 Lunar Clubman SB. It comprises a new label and a Certificate of Compliance. Currently the only label is an aluminium one under the door, presumably I stick the new label in the gas locker. I have posted details and a picture here.  

I had to order it through a Lunar dealer although Lunar were quite helpful about the process when I first emailed them.

 

Dave 

 

Thanks for the information, it helps me explain matters a bit better.  

 

I have looked at the picture you posted a link to, and, for the benefit of others it’s below

 

16DC715E-F2E3-4176-A758-5AA03483F3E3.thumb.png.2edfa588d3ab6ba7216fb43206960e90.png

 

 

Now compare that to the one that’s on the side of my (current) caravan. Yours has what I assume to be the caravans VIn number AND both the MTPLM /MRO & MOST IMPORTANTLY the Max axle weights, so would be accepted by any enforcement officer as being the caravans max gross weight (MTPLM) 

 

Mine on the other hand ONLY shows the caravan model, the MRO and the MTPLM, No VIN number and no axle weight.  

 

I would just point out  there is no other decal in the gas locker, I have checked VERY carefully. It’s one of the last Olympus’s made so, even though it was made in 2013/4 as it wasn’t a NEW model it didn’t, at that time, have to have the gas locker decal that all NEW models must now have.

 

8D1D46A5-E394-4182-8410-14D25B149C49.thumb.jpeg.62f25b7a90ba88045b771c4e2b03321d.jpeg

 

When I get my new caravan it will have a gas locker decal showing an MTPLM of 1450 Kg (as per your Elddis one with MRO MTPLM and max axle weight as well)  and another, as per the picture above, that will show 1382 Kg. If I purchase the “upgrade” from Bailey the ONLY new decal they supply is as above with the higher weight showing. The gas locker one does not alter!! 

 

So which one will show the LEGALLY ENFORCEABLE MTPLM, the one as per the ONLY one fitted by Elddis (that shows all the information detailed above, that’s on a tamperproof decal in the gas locker,) OR the easily removed external one with scant information on it.  

 

Remember, Bailey are saying the one in the gas locker shows

“ the maximum weight allowed” 

 

If I was still at work and got involved with weighing it then I have no doubt at all that I would use the tamperproof one in the gas locker because it shows VIN number, axle and max gross weights.  

 

Now,  just suppose a rig that gets stopped has a max train weight of EXACTLY 3500 Kg if you use the external 1382Kg decal,  and is being driven by someone who only has a Cat B licence (so can only drive a rig not EXCEEDING 3500Kg ) he is (just) legal and his licence covers him.

 

BUT If the Police Officer is aware of, and uses the gas locker decal (which shows the MTPLM to be 1450Kg ) the rig will be then be OVER 3500Kg train weight by 68Kg (not a lot but the legal limit is the legal limit)

 

The implications are serious.  the poor driver (who bought the caravan thinking it’s MTPLM was 1382 Kg) will be driving WITHOUT A LICENCE because the other decal WHICH IN BAILEYS WORDS shows the “Maximum weight allowed!!!” Puts the rig over his (licence) restriction of 3500 Kg.

 

He also CANNOT have insurance because a condition of any insurance is that the driver “Must hold, or has held and is not disqualified from holding, a licence to drive that class of vehicle.  

 

So it’s no licence AND no insurance, mega fine and many points.  

 

So so as you can see the ambiguity in the variance of information  displayed is NOT JUST about a bit of extra payload, it’s far more serious than that.  

 

Andy

Edited by Mr Plodd

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I'm not so sure about Dave's Lunar upgrade sticker.

 

  1. Firstly MIRO isn't required information on a VIN plate, though I'm not sure if it's presence invalidates it as a mandatory plate.
  2. Axle 1 should read the noseweight limit and the van's axle limit should appear as axle 2. On a twin axle they appear as axoles 2 and 3.
  3. There's no Type Approval number on the sticker.

I suspect that Lunar have supplied a sticker as a replacement for the alloy plate used on pre 2012MY vans and that it has the info that was required in 2012 on an existing model. It isn't a VIN plate as required by Type Approval regs, but such a plate isn't necessary for a 2012MY van.

 

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Regardless of whether the caravan manufacturer is a Stage 2 or a Stage 1 manufacturer, the statutory plate must bear the name of the caravan manufacturer. Any plate bearing the name of the chassis manufacturer would not be the valid statutory plate.

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50 minutes ago, Steamdrivenandy said:

I'm not so sure about Dave's Lunar upgrade sticker.

 

  1. Firstly MIRO isn't required information on a VIN plate, though I'm not sure if it's presence invalidates it as a mandatory plate.
  2. Axle 1 should read the noseweight limit and the van's axle limit should appear as axle 2. On a twin axle they appear as axoles 2 and 3.
  3. There's no Type Approval number on the sticker.

I suspect that Lunar have supplied a sticker as a replacement for the alloy plate used on pre 2012MY vans and that it has the info that was required in 2012 on an existing model. It isn't a VIN plate as required by Type Approval regs, but such a plate isn't necessary for a 2012MY van.

 

 

The MIRO may appear on the statutory plate, but as it isn't required, it must be distincly separated from mandatory data by a clear line.

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Interestingly the new Bailey door plates do now include the type approval number but still no vin.  

 

I don't think a b licence holder has any worries in the uk but it would be interesting to know what would happen on the continent.   

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1 hour ago, Mr Plodd said:

8D1D46A5-E394-4182-8410-14D25B149C49.thumb.jpeg.62f25b7a90ba88045b771c4e2b03321d.jpeg

 

If you read the above Bailey label carefully, you will see that Bailey don't even claim it to be a statutory plate. They reference a "Certification Scheme, Leisure Accommodation Vehicles". This would certification according to BS EN 1645-1, but not whole vehicle type approval, which is what the statutory plate is required to certify.

 

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29 minutes ago, handyandy said:

I don't think a b licence holder has any worries in the uk

 

Why not??

 

The law is totally unambiguous in regards to licence categories and gross weight. There is NO “overlap”  once you get over 3500, even by a single Kg, you cannot drive it on a Cat B licence.  No if’s and’s or but’s 

 

 

Edited by Mr Plodd

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15 minutes ago, handyandy said:

Interestingly the new Bailey door plates do now include the type approval number but still no vin.  

 

I don't think a b licence holder has any worries in the uk but it would be interesting to know what would happen on the continent.   

 

It depends on how well the powers-that-be on the Continent are informed. Normaly they would disregard any non-statutory plate, but perhaps with a bit of luck one may bluff one's way into convincing an officer of the legitimacy of another plate.

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In the uk it is an offence to sell a none approved trailer.  Bailey have ECWVTA. To do this they need the statutory plate, which is in the gas locker.  

 

Records need to be kept of all trailers sold. The caravan industry do this via CRiS, run by the NCC.  So do they record MTPLM and does this get updated when you buy an uprate?

 

 Any other vehicle type approval is checked at registration. When registered it can uprated, downplated and otherwise altered under our national legislation. Most alterations are notifiable and it may be summoned for a test. It is unlikely it would get tested for a downplate however.  

 

As o2 trailers are not registered no alteration is notifiable. There is nobody to notify! Therefore it can be downplated by the manufacturer at will.  

 

 

 

 

Edited by handyandy

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Any upgrading or downgrading weights of trailers and vehicles has to go through the  type approval process if whole vehicle type approved .

 

Dave

Edited by CommanderDave

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8 minutes ago, CommanderDave said:

Any upgrading or downgrading weights of trailers and vehicles has to go through the the type approval process if whole vehicle type approved .

 

Dave

 

Before registeation yes, after registration no.  

Edited by handyandy

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It is illegal to alter any Vin plate and the only legal method is by the manufacturer supplying a new plate .

 

Those days are gone . Everything now has vin plates and CoC .

 

My mate wishes it was that easy he spends hundreds of thousands of pounds upgrading vehicles on type approval between SV tech and vehicle manufacturers .

 

 

Dave

Edited by CommanderDave

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25 minutes ago, handyandy said:

Before registeation yes, after registration no.  

 

Whether regisitered or not, the VCA must be notified if a change such as upplating is not covered by existing type approval and they will require resubmission. If this is not the case an uprated caravan could never be registered in an EU country with the uprated figure if the owner moves abroad.

Edited by Lutz

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49 minutes ago, CommanderDave said:

It is illegal to alter any Vin plate and the only legal method is by the manufacturer supplying a new plate .

 

Those days are gone . Everything now has vin plates and CoC .

 

My mate wishes it was that easy he spends hundreds of thousands of pounds upgrading vehicles on type approval between SV tech and vehicle manufacturers .

 

 

Dave

 

You don’t alter the vin plate, you just add another supplementary plate.  

 

You mate must be making changes pre reg to spend that much!

 

39 minutes ago, Lutz said:

 

Whether regisitered or not, the VCA must be notified if a change such as upplating is not covered by existing type approval and they will require resubmission. If this is not the case an uprated caravan could never be registered in an EU country with the uprated figure if the owner moves abroad.

 

 

Yes if it gets exported it would revert to the coc.  

Edited by handyandy

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Please Reference the law/ regulation that gives legitimacy to the supplementary plate as you describe it.  

 

There is an an old saying in my world.  “If it isn’t written down it is only a rumour” 

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13 hours ago, Mr Plodd said:

 

Why not??

 

The law is totally unambiguous in regards to licence categories and gross weight. There is NO “overlap”  once you get over 3500, even by a single Kg, you cannot drive it on a Cat B licence.  No if’s and’s or but’s 

 

 

I thought that was changed and a person with a B licence exceed the 3500kg and could tow an unbraked trailer as long as the train weight of the vehicle was not exceeded?

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2 minutes ago, Durbanite said:

I thought that was changed and a person with a B licence exceed the 3500kg and could tow an unbraked trailer as long as the train weight of the vehicle was not exceeded?

 

Category B - if you passed your test on or after 1 January 1997

You can drive vehicles up to 3,500kg MAM with up to 8 passenger seats (with a trailer up to 750kg).

You can also tow heavier trailers if the total MAM of the vehicle and trailer isn’t more than 3,500kg.

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13 hours ago, handyandy said:

 

You don’t alter the vin plate, you just add another supplementary plate.  

 

Yes if it gets exported it would revert to the coc.  

 

Construction and Use Regulations don't Talk about a VIN plate, nor of a supplementary plate. There is only one plate that the regulations refer to and that is the statutory plate. What has to be displayed on that is clearly defined. The Certificate of Conformity must always agree with what is on the statutory plate. The statutory plate is merely a summary of what is on the CoC, to save having to carry the CoC around with you all the time.

 

Edited by Lutz

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I commend the thread starter trying to get an answer to the labels and weights.

What the thread doesn't need is the technical arguments about type approval/stage 1/stage 2 etc because we end up loosing site of the original thread.

Most people don't give a stuff about all that, they want to know which label is correct.

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16 minutes ago, warrenb said:

I commend the thread starter trying to get an answer to the labels and weights.

What the thread doesn't need is the technical arguments about type approval/stage 1/stage 2 etc because we end up loosing site of the original thread.

Most people don't give a stuff about all that, they want to know which label is correct.

 

Because plating requirements are so tied in with type approval, it's impossible to separate one from the other.

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Wrong, for the standard caravaner they just want to know what label to look at, they couldn't give a stuff about type approval or even what that is.

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Just now, warrenb said:

Wrong, for the standard caravaner they just want to know what label to look at, they couldn't give a stuff about type approval or even what that is.

 

I think the question has been answered in this thread several times that the label to look at is the label that displays all the information that type approval requires.

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10 minutes ago, warrenb said:

Wrong, for the standard caravaner they just want to know what label to look at, they couldn't give a stuff about type approval or even what that is.

 

 

It might not be of interest to the owner but it is to authorities and can impact a owner if they are illegally on the road with no licence and insurance .

 

At the end of the day  responsibility is with the driver in law and ignorance is no excuse .

 

Dave

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Exactly, which as been answered. So then the owner knows what label to look for. It doesn't need 4 pages of type approval this, chassis loads that, stage 1/stage 2 the other.

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17 minutes ago, warrenb said:

Exactly, which as been answered. So then the owner knows what label to look for. It doesn't need 4 pages of type approval this, chassis loads that, stage 1/stage 2 the other.

 

I'm afraid it does if some people post misunderstood or misleading information. The background and sources have to be made clear, otherwise it's just one persons word against another's.

 

An owner buys a van based on its spec. They use the manufacturer's website and/or brochure to access that spec. Neither of those sources will tell them all the figures that are on the mandatory plate, at least one of which they need, if they're a B licence holder, to ensure that they are legally authorised to tow that van. It seems ridiculous that UK manufacturer's continue to operate such a charade and nobody calls them out on it.

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