Jump to content
Sign in to follow this  
Paul90125

MTPLM Update

Recommended Posts

Posted (edited)

Aren't the references to down plating a commercial vehicle misleading in relation to caravans where the change of plate requires no legally defined documentation?

 

https://www.gov.uk/specialist-tests-for-lorries/change

 

https://www.gov.uk/government/publications/details-of-notifiable-alterations-or-application-for-a-change-of-plated-details-of-a-goods-motor-vehicle

 

Edited by beejay

Share this post


Link to post
Share on other sites
1 hour ago, Lutz said:

 

One cannot have two different definitions for the same term or else the result is always ambiguous. MTPLM is defined quite clearly in the respective legislation. Any figure lower than that cannot be a maximum. The figure that the NCC has defined (in accordance with BS EN 1645-2) and which the manufacturer displays on a label next to the door is neither a maximum nor technical (because it is based purely on a calculated value, not on any technical constraints), so both the 'M' and the 'T' are out of place if called an MTPLM. Therefore, another term must be used to describe it.

 

Surely it follows that if the figure allocated by the manufacturer is neither 'maximum' nor 'technical' how can it be used as a limit for driving licence qualification purposes? Calling it an MTPLM is a misnomer, something akin to calling an apple a pear.   

Share this post


Link to post
Share on other sites
53 minutes ago, Durbanite said:

TBH sometimes I think that the DVSA or VOSA as they were previously known make it up as they go along.  I do recall a copy of a letter being posted on a caravan forum where the VOSA person definitely stated that the sticker on the body work of the trailer could not be used to prosecute as it was not a mandatory plate. 

 

However perhaps things have changed however Lutz is correct in stating that MTPLM is not used in any legislation so how can any DVSA agent prosecute if the legislation does not exist even on post 2012 trailers?  Best is to stay within the guidelines offered by the caravan manufacturer and avoid any hassles!  :D

 

What is referred to in legislation is Maximum AUTHORISED Mass (MAM) which is of course not the same as MaximumTECHNICALLY Permitted Laden Mass.  

 

Andy

  • Like 1

Share this post


Link to post
Share on other sites
54 minutes ago, Mr Plodd said:

 

OK, why don’t YOU try and get a wholly definitive answer as I did? Rather than just posting the arguments I already have put to both the DFT and DVSA. 

 

I dont disagree with the the fact that it’s bizarre and totally illogical, but I have tried my hardest on behalf of everyone, rather than just post disagreements as you are doing. 

 

Andy

 

I fully respect your attempt to clarify things and you are to be commended for your efforts, but the replies that you got from the DFT and DVSA were not really definitive as they didn't address the issues that I raised such as having two definitions for the same term (and there must be two or else they wouldn't have different values). As the DFT and DVSA were of no help, and as you say, the situation as it stands is bizarre and illogical, it would seem that final clarification can only be brought about by raising the issue in a court of law. Living here on the Continent that would be difficult for me to do, so I see my responses simply to highlight arguments that I firmly believe to be valid and rational and which could therefore be used as defence in a possible court case.

 

37 minutes ago, chrisn7 said:

Mr Plodd has described things correctly. A newly purchased van would come with its standard MTPLM, or it may be upgraded at customer request. Either way you submit your proposal to the insurer who never asks the MTPLM and must therefore be unconcerned that it is a modification carrying an increased risk. Therefore a later plate upgrade is no different from having it done at new.

 

Maybe you have missed out on previous threads in this forum concerning cases where two different weights are displayed on a caravan, both of which are referred to as an MTPLM.

 

33 minutes ago, Durbanite said:

 

However perhaps things have changed however Lutz is correct in stating that MTPLM is not used in any legislation so how can any DVSA agent prosecute if the legislation does not exist even on post 2012 trailers?  Best is to stay within the guidelines offered by the caravan manufacturer and avoid any hassles!  :D

 

MTPLM is defined and used in legislation. What I am saying is that it is inappropriate to call any figure that is lower than the type approved MTPLM to also call an MTPLM, although it obviously is.

Share this post


Link to post
Share on other sites
10 minutes ago, Mr Plodd said:

 

What is referred to in legislation is Maximum AUTHORISED Mass (MAM) which is of course not the same as MaximumTECHNICALLY Permitted Laden Mass.  

 

Andy

 

Both terms are used in legislation. The difference between the two is not in interpretation, but when the respective legislation was written. Older legislation, prior to the implementation of EU directives, refers to maximum authorised mass, later amendments use the term maximum technically permissible laden mass, in line with the EU directives that they refer to. When you read the definitions, as defined in the respective legislation, you will see that there is no substantial difference between the two, only that the wording, but not the meaning, is slightly different.

Share this post


Link to post
Share on other sites

Lutz I am beginning to think that you are arguing with yourself?

 

I have just been out to check our gas locker on our 2018 caravan and there is no sticker or plate to be seen that mentions any weights.  Only the sticker by the door on the caravan body and easy enough to peel off that sticker.

Share this post


Link to post
Share on other sites
5 hours ago, Durbanite said:

Lutz I am beginning to think that you are arguing with yourself?

 

I have just been out to check our gas locker on our 2018 caravan and there is no sticker or plate to be seen that mentions any weights.  Only the sticker by the door on the caravan body and easy enough to peel off that sticker.

 

Since 2017 Hymer UK have fitted composite stickers on their vans that contain both the information that's required by Type Approval legislation  and on the other side of a horizontal line the info that the NCC specify, which isn't legally required. They fudge the MTPLM issue by not putting any descriptive words or letters beside the axle/chassis limit on the Type Approval area of the sticker and having 'MTPLM' written beside the allocated weight limit in the NCC area. Most owners appear not to notice the higher limit figure. Of course, if they're upgraded when first sold then both figures match anyway.  

Share this post


Link to post
Share on other sites
Posted (edited)
6 hours ago, Steamdrivenandy said:

 

Since 2017 Hymer UK have fitted composite stickers on their vans that contain both the information that's required by Type Approval legislation  and on the other side of a horizontal line the info that the NCC specify, which isn't legally required. They fudge the MTPLM issue by not putting any descriptive words or letters beside the axle/chassis limit on the Type Approval area of the sticker and having 'MTPLM' written beside the allocated weight limit in the NCC area. Most owners appear not to notice the higher limit figure. Of course, if they're upgraded when first sold then both figures match anyway.  

 

The reason why there aren't any descriptive words or letters next to the MTPLM and max. axle loads on the statutory plate is because the plate has to be common throughout Europe but the term MTPLM is purely English and wouldn't be understood or identified as such in a non-English speaking country. Therefore, only the number '1' is always used to identify the MTPLM, '2' gross train weight (where applicable), and all further numbers the max. permissible axle loads.

 

Edited by Lutz
  • Like 1

Share this post


Link to post
Share on other sites

A manufacturer can have a vehicle type approved to any value they choose, provided that value can be met mechanically.

 

That vehicle can then by the manufacturer if so intent be regarded as a platform.

That platform can then have a lower value MTPLM/MAM imposed on it to meet whatever proposed final use said manufacturer requires of it, or variants of said platform (dealer specials, etc)

 

This lower figure then becomes the maximum figure for legal use upon the road.

 

The issue you are having is :-

Do the manufacturers have any legal right to impose a lower value as to their products?

 

Answer, Yes.

 

If not then the products they make wouldn't be allowed on UK roads.

 

Share this post


Link to post
Share on other sites
2 minutes ago, Wellys and Mac said:

A manufacturer can have a vehicle type approved to any value they choose, provided that value can be met mechanically.

 

That vehicle can then by the manufacturer if so intent be regarded as a platform.

That platform can then have a lower value MTPLM/MAM imposed on it to meet whatever proposed final use said manufacturer requires of it, or variants of said platform (dealer specials, etc)

 

This lower figure then becomes the maximum figure for legal use upon the road.

 

The issue you are having is :-

Do the manufacturers have any legal right to impose a lower value as to their products?

 

Answer, Yes.

 

If not then the products they make wouldn't be allowed on UK roads.

 

 

You then have two different weights and specifications using the same term, there can only be one legally enforcible maximum.

 

So whilst you are correct in saying they can impose a lower value the grey area is what they choose to call it.

Share this post


Link to post
Share on other sites
Posted (edited)
16 minutes ago, Grandpa Steve said:

 

You then have two different weights and specifications using the same term, there can only be one legally enforcible maximum.

 

So whilst you are correct in saying they can impose a lower value the grey area is what they choose to call it.

Regarding the "Term" well no, because it is the same intent.

 

Imagine I call a wheel a wheel, but you call it a brick! :blink:

Now that certainly would cause confusion.

 

The discussion depends on how you view the process and end result.

 

I see it as a pyramid.

The top is Type approval MTPLM/MAM.

Next level down are mechanical component plated weights.

Next layer down door sticker MTPLM.

Edited by Wellys and Mac

Share this post


Link to post
Share on other sites
2 minutes ago, Wellys and Mac said:

Regarding the "Term" well no, because it is the same intent

 

 

You cannot have two legally enforceable and different weights displayed on two different plates.

 

The manufacturers have caused this issue,  by using smoke and mirrors to allow drivers with B category licences to pull car/caravans combinations that have a higher weight than their licence category should allow.

 

But as has been said before, it would take a court case to test their rationale.

 

Share this post


Link to post
Share on other sites
1 minute ago, Grandpa Steve said:

 

You cannot have two legally enforceable and different weights displayed on two different plates.

 

The manufacturers have caused this issue,  by using smoke and mirrors to allow drivers with B category licences to pull car/caravans combinations that have a higher weight than their licence category should allow.

 

But as has been said before, it would take a court case to test their rationale.

 

But you can because the plates have two different intents.

Type approval is for the manufacturers use formost.

Door plate is for the road user utmost.

 

I think it's a bit unkind to say smoke and mirrors, your correct about placing a lower MTPLM to increase the availability of their product, but wrong to say the user is towing a heavier caravan because the door plate is enforceable so restricts the licence holder to their category.

 

I disagree regarding a court case, as its standard and a wide spread practice not just with caravans but a whole host of trailers and vehicles.

 

Let's agree to disagree, :)

Share this post


Link to post
Share on other sites
27 minutes ago, Wellys and Mac said:

 

The issue you are having is :-

Do the manufacturers have any legal right to impose a lower value as to their products?

 

Answer, Yes.

 

 

Of course there's nothing to stop a manufacturer from specifying an MTPLM lower than what would theoretically be possible given the design criteria, but then he should display that lower value on the statutory plate.

It's bizarre that the same manufacturers abide by this practice for the motorhomes that they produce but not for their caravans.

 

3 minutes ago, Wellys and Mac said:

But you can because the plates have two different intents.

Type approval is for the manufacturers use formost.

Door plate is for the road user utmost.

 

 

But only one can be legally enforceable and the law only makes reference to what's displayed on the statutory plate.

Share this post


Link to post
Share on other sites
1 minute ago, Lutz said:

 

Of course there's nothing to stop a manufacturer from specifying an MTPLM lower than what would theoretically be possible given the design criteria, but then he should display that lower value on the statutory plate.

It's bizarre that the same manufacturers abide by this practice for the motorhomes that they produce but not for their caravans.

 

 

But only one can be legally enforceable and the law only makes reference to what's displayed on the statutory plate.

What you suggest about statutory plates would require each variant required type approval, under the current system it's only the "mother" caravan so to speak.

 

Sorry I dont think I can add anything more to the discussion. 

 

 

 

Share this post


Link to post
Share on other sites
Posted (edited)
23 minutes ago, Wellys and Mac said:

What you suggest about statutory plates would require each variant required type approval, under the current system it's only the "mother" caravan so to speak.

 

Sorry I dont think I can add anything more to the discussion. 

 

 

 

 

Type approval can be generic to cover a whole range of weights for one particular model. It doesn't have to be specific for just one value.  It just has to be documented like that in the type approval itself. No new type approval is required if the value displayed on the statutory plate is within the range that has already been approved.

 

Edited by Lutz

Share this post


Link to post
Share on other sites
1 hour ago, Wellys and Mac said:

 

 

Sorry I dont think I can add anything more to the discussion. 

 

 

 

 

I think you have done an excellent job of explaining the situation. I attempted to get to the very bottom of it some while ago. In the end I spoke, at length, to someone at DVSA who clearly knew his subject. It was a fairly technical discussion because, like him, I understand both how legislation is written and enforced. I posted a summary of that conversation on the previous and very lengthy thread. In the absence of any further information from DVSA DFT I will stick with the information I have gleaned. 

 

Some on this forum are, and it’s not meant in a derogatory manner, “back room lawyers” (who have no experience in respect of legislation and how it’s used) who THINK they know better than peoples who’s whole lives revolve around the subject matter.

 

I have repeatedly challenged others to take up the crusade as I feel I have exhausted all possible avenues, no-one has been prepared to do that yet they STILL insist on disagreeing with someone who has. So come on all you “Nay sayers” prove me wrong!!

 

To sum up “You cannot please all of the people all of the time” 

 

Andy

  • Like 1

Share this post


Link to post
Share on other sites
2 hours ago, Mr Plodd said:

Some on this forum are, and it’s not meant in a derogatory manner, “back room lawyers” (who have no experience in respect of legislation and how it’s used) who THINK they know better than peoples who’s whole lives revolve around the subject matter.

 

Andy

 

You don’t have be a back room lawyer to discuss and debate what is still a stupid situation.

 

Lutz is very knowledgeable in these subject and has contributed much to the discussion based on his experience, you do him and anyone else who has knowledge a disservice by trying to play down that.

 

You have an answer you are happy with, others don’t.

 

Just because people don’t agree with you, doesn’t mean they have to be challenged to take up a crusade.

 

Its called agreeing to disagree.

 

 

Share this post


Link to post
Share on other sites

I am not disputing that, but I have spent considerable time and effort trying to get a definitive answer from DVSA/DFT/caravan manufacturers, and I have posted all of the information I have gleaned for the benefit of others. 

 

Others (I am deliberatly not naming them) continually post their opinions and views, but they have NOT attempted to obtain any facts or information from anyone else (or if they have that information has not been shared) 

 

I am the first to agree that the situation is bordering on farcical, but I have posted as much information as possible and NOT just relied on my own views/opinion. 

 

Andy

  • Like 1

Share this post


Link to post
Share on other sites
Posted (edited)

As I've said before, the situation would be so easy to put right. It can therefore only be due to resistance on the part of the NCC. It would be just as easy for the manufacturer to supply a new statutory plate with a higher MTPLM as it is to supply a new label to go next to the door.

Edited by Lutz

Share this post


Link to post
Share on other sites

We have recently taken delivery of a 2019 Bailey Cartagena, plate but side of door 1682kg giving payload of 160kg take out motor mover & battery and you're down to 110kg which is not a lot. Found weight plate in gas locker that says 1800kg In process of ordering upgrade at £60, pure paper job. Jury may be out on legal necessity but I'll be happier as reduced possibility of 'discussion' with plod if pulled. Luckily car can pull 1900kg and I'm an old bigger so don't have licence restriction.

Share this post


Link to post
Share on other sites
Posted (edited)

So where does the door plate on  my Clubman stand.

Manufacturers declared MTPLM is 1470kg.

Axle maximum for which an upgrade can be purchased is 1500kg.

Both weights are recorded on the door plate.

6A19E929-DB4B-499E-8D20-D078BA655359.jpeg

Edited by hp100425ev

Share this post


Link to post
Share on other sites

Maximum mass allowed is 1470 kg would make no difference if you had a 2000 kg axle limit .

 

 

 

 

Dave

Share this post


Link to post
Share on other sites

IIRC Lunar adopted a hybrid style exterior plate around the same time as Elddis/Hymer UK, that is in 2017. The info on it complies with both Type Approval and the NCC's spec.

 

You'll note that the 1470kg on the Type Approved part of the label has no definition against it, whilst the lower NCC portion has 'MTPLM' against the same figure. Anyone looking at the plate would immediately be of the opinion that the legal MTPLM is 1470kg because the figure appears twice and is labelled accordingly once. However thinking logically what's the point of a 1500kg limit on the axle when your only allowed to load to 1470kg overall and part of that 1470kg will be transferred to the car via the noseweight/hitch? It's likely that if you stick to the limits you're only ever going to load the axle to about 1400kg.  Presumably Lunar don't label the top 1470kg as MTPLM because such labelling is not required under Type Approval regs and it would immediately raise a query in the mind of any owner as there's a higher axle limit below  it.

Share this post


Link to post
Share on other sites
Posted (edited)

At least the statutory plate above the little box at the bottom agrees with the figure next to the MTPLM shown in that box. The statutory plate is fully in accordance with type approval requirements.

 

Edited by Lutz

Share this post


Link to post
Share on other sites

Join the conversation

You can post now and register later. If you have an account, sign in now to post with your account.

Guest
Reply to this topic...

×   Pasted as rich text.   Restore formatting

  Only 75 emoji are allowed.

×   Your link has been automatically embedded.   Display as a link instead

×   Your previous content has been restored.   Clear editor

×   You cannot paste images directly. Upload or insert images from URL.

Sign in to follow this  

×
×
  • Create New...