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Alan Stanley

MTPLM weight upgrades available

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7 hours ago, Lutz said:

The so-called “upgrades” aren’t really upgrades at all, but they just bring a label by the door in line with what is there already. A true upgrade requires a technical change to the finished product, like a different axle with a higher rating.

 

 

A manufacturer can designate whatever MTPLM they wish PROVIDED that figure doesn't exceed the MTPLM that the type approval shows.

 

It’s pretty common with “smaller” HGV’s They are type approved at say 7750 kg, so requires an HGV licence etc. However, if you wish to carry bulky items rather than heavy items you can have the lorry with a plated MTPLM of 7490 Kg  So no HGV licence CPC card etc is required because it’s plated at under 7500kg.

 

The “Ministry Plate” will show 7490 kg but the Makers VIN plate will still show 7750. It’s the Ministry Plate that is used for all Enforcement purposes. The vehicle is identical in all respects EXCEPT for the plated MTPLM. That’s the position with caravan plates as well. 

 

Andy

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Posted (edited)
6 hours ago, Mr Plodd said:

 

A manufacturer can designate whatever MTPLM they wish PROVIDED that figure doesn't exceed the MTPLM that the type approval shows.

 

It’s pretty common with “smaller” HGV’s They are type approved at say 7750 kg, so requires an HGV licence etc. However, if you wish to carry bulky items rather than heavy items you can have the lorry with a plated MTPLM of 7490 Kg  So no HGV licence CPC card etc is required because it’s plated at under 7500kg.

 

The “Ministry Plate” will show 7490 kg but the Makers VIN plate will still show 7750. It’s the Ministry Plate that is used for all Enforcement purposes. The vehicle is identical in all respects EXCEPT for the plated MTPLM. That’s the position with caravan plates as well. 

 

Andy

 

Non-commercial vehicles don't have  a 'Ministry Plate'. The only plate that is recognised in UK legislation for vehicles under 3500kg is the respective statutory plate on the car and the trailer (caravan). There are no provisions for having two MTPLMs displayed on a caravan.

Besides, the "Ministry Plate" does not specify the maximum technical permissible laden mass (MTPLM) but the maximum gross vehicle weight, which is not necessarily a technical limit. As two different terms are used, there can be no confusion, but there would be if both were called MTPLM such as is the case on a caravan.

Edited by Lutz

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5 hours ago, Lutz said:

 

Besides, the "Ministry Plate" does not specify the maximum technical permissible laden mass (MTPLM) but the maximum gross vehicle weight, which is not necessarily a technical limit. As two different terms are used, there can be no confusion, but there would be if both were called MTPLM such as is the case on a caravan.

 

I agree that non commercial vehicles do not have a ministry plate. However despite the fact that a commercial vehicle can have an MTPLM greater than the weight shown on the Ministry Plate it is the weight on the Ministry Plate that is used for all Enforcement purposes. If it actually weighs more than the max shown on the Ministry plate, but LESS than the makers VIN plate max an offence is committed. 

 

Modern caravans, on the whole, do indeed often have two ‘plates” fitted. One in the gas locker which shows the type approval Max weight, and another, on the outside, (provided and fitted by the maker) which shows (usually) a lower weight and it is THAT figure that is used for enforcement. 

 

Imagine this scenario. (Which uses real life figures)

My car has a MAM of 2110 kg  with a MGTW of 3710, so in theory it can tow a caravan with a Gross weight of 1600 kg.

My caravan left the factory with an MTPLM of 1450kg so is well within my cars towing limit.

 

HOWEVER if you add the car and caravans max weights together they come to 3550kg so require a B+E licence.

 

BUT  the caravan left the factory with its MTPLM shown on an external decal, as 1397kg. This added to the cars MAM gives a gross train weight of 1497kg so,  rbeing under 3500kg (by just 3) a B+E licence is NOT required.

 

So if I lend my caravan, with an MTPLM figure on the external decal showing a MTPLM of 1397kg to my son, who passed is test post ‘97 so doesn’t have a B+E licence, he CAN legally drive it on the road EVEN THOUGH the MTPLM figure on the “Type Approval” decal in the gas locker shows a figure that, combined with the cars MGW would put it OVER the 3500kg threshold and require him to hold B+E

 

And THAT is why Caravan manufacturers put the lowest possible MTPLM on the external decal (and the C ofC) It opens up the number of possible purchasers.

 

I have had a lengthy, and highly detailed, conversation with a senior man from VOSA, he confirmed to me that IF (note the If!) a caravan has an external, manufacturers supplied, decal/sticker/plate that shows an MTPLM then THAT’S  the figure they work from and not the Type Approval one that’s “hidden” in the gas locker.See above scenario!

 

Yes it’s daft, yes it’s complex, but that’s how “The system” operates. I didn’t make the rules! 

 

Andy

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Posted (edited)
33 minutes ago, Mr Plodd said:

 

 

Modern caravans, on the whole, do indeed often have two ‘plates” fitted. One in the gas locker which shows the type approval Max weight, and another, on the outside, (provided and fitted by the maker) which shows (usually) a lower weight and it is THAT figure that is used for enforcement. 

 

 

 

The 'plate' by the door can only be used for law enforcement purposes if it's there. However, all the information that is required for law enforcement purposes is already shown on the statutory plate. That means that the plate next to the door is entirely superfluous. Nothing would be missing if it's removed so it can't be illegal just to remove it. Legislation does not recognise two different MTPLM's being present on the same vehicle, not even for heavy goods vehicles displaying the 'Ministry Plate'. In the case of the latter, one value is the MTPLM, the other is the gross vehicle weight. For vehicles under 3500kg, the two are the same.

 

Edited by Lutz

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Posted (edited)

So how exactly do you sort out the scenario I outlined? 

 

The weights  quoted are from my car and caravan. Using your argument if my son borrows my car and caravan he would be breaking the law, because the gas locker decal weight would put the rig over 3500kg yet caravans are sold, in their hundreds, where the manufacturer quotes the MTPLM that is LESS than the Type Approval figure and THAT weight is what is displayed in a prominent external position not hidden away in the gas locker) How do you square that circle!

 

 I would have expected someone to have been taken to court over this issue at some point. But I can find no information that such a case has been brought. 

 

Andy

Edited by Mr Plodd

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What you need to bear in mind is that the standard payload that UK manufacturer's allocate to a model is determined by reference to the NCC Minimum Payload Regulation. It's not a legal regulation but it is a formula that all members of the NCC agree to respect. Also note it is the 'minimum' and manufacturer's are at liberty to provide more as standard, but they don't. 

 

The reason they don't is because there is great competition within the market to be lightest. This already existed before the B+E issue came along, but that's given it extra impetus. Indeed it's the ongoing quest to be lightest that drove the NCC to introduce the minimum formula in the first place, otherwise there was a danger of manufacturer's going down silly paths to be able to quote lower weights then their competitors. The minimum was introduced to provide a level playing field.

 

The formula is based on so many KG per berth and so many KG per metre length of van, plus 50kg for a basket of standard items (including a light battery). That's why 4 berth vans built using the same bodyshell have the same payload allowance and why 2 berth vans have slightly less because they have two less berths and are a bit shorter.

 

Trouble is that the formula was dreamt up before movers and large batteries became the norm, so the allowance now seems small. However I suspect manufacturer's won't let the NCC increase the formula to more realistic levels as that will mean MTPLM's rising and potentially losing sales to B only licence holders.  Also it's not a politically good thing to be seen doing in these weight conscious eco worrying times. 

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Posted (edited)
4 hours ago, Mr Plodd said:

So how exactly do you sort out the scenario I outlined? 

 

The weights  quoted are from my car and caravan. Using your argument if my son borrows my car and caravan he would be breaking the law, because the gas locker decal weight would put the rig over 3500kg yet caravans are sold, in their hundreds, where the manufacturer quotes the MTPLM that is LESS than the Type Approval figure and THAT weight is what is displayed in a prominent external position not hidden away in the gas locker) How do you square that circle!

 

 I would have expected someone to have been taken to court over this issue at some point. But I can find no information that such a case has been brought. 

 

Andy

 

If the powers-that-be are happy with using the figure displayed on a label next to the door so be it, but what I am saying is that if the label next to the door is not present, all the information that they need for law enforcement purposes is shown on the statutory plate and there is no need for that label. The statutory plate fulfils all legal requirements.

 

Edited by Lutz

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Out of interest, on caravans manufactured before the statutory plate was brought in with just the plate by the door, should the door plate have come adrift and disappeared (which nearly happened with my last caravan) where would roadside inspecting agencies obtain a caravans MTPLM figure from then?

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The manufacturer if they were specifically concerned.

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Thinking specifically for licence entitlement and the fact that certain manufacturers no longer exist.

 

 

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Posted (edited)

I guess that in the event of no plate having been applied by the caravan manufacturer there will still be a plate applied by the chassis manufacturer and this would then be used. Certainly, chassis manufactured by AlKo or BPW in Germany will always have a plate as they were always subject to national type approval, even before EU type approval came into being. I cannot imagine that such chassis bound for export to the UK did not have a plate. To enable traceability in the event of a recall or possible legal action regarding product liability there must be a plate somewhere.

 

Edited by Lutz

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But in the case where the visible plate plate fitted by the door had disappeared, a plate which stated the MTPLM, could a chassis plate if there was one have a higher rating thus causing possible problems for a B only licence holder?

 

 

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15 minutes ago, Griff said:

But in the case where the visible plate plate fitted by the door had disappeared, a plate which stated the MTPLM, could a chassis plate if there was one have a higher rating thus causing possible problems for a B only licence holder?

 

 

That is a distinct possibility, yes. Not only if the label next to the door had disappeared but also if the owner takes the caravan abroad and the powers-that-be there don't recognise what's on that label or don't understand what MTPLM means.

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8 hours ago, Lutz said:

 

If the powers-that-be are happy with using the figure displayed on a label next to the door so be it, but what I am saying is that if the label next to the door is not present, all the information that they need for law enforcement purposes is shown on the statutory plate and there is no need for that label. The statutory plate fulfils all legal requirements.

 

 

So, going back to the scenario with my caravan and my son borrowing it, just suppose for the sake of argument, that some Oik removes the external decal whilst he is on a campsite, and when he leaves the site he is stopped by VOSA. The combined weight (according to the gas locker plate) exceeds 3500kg by 43kg. BUT the manufacturer (Bailey) designates that model as having a weight that puts the rig just UNDER 3500kg at 3497kg (actual figures for my van) 

 

Son gets summonsed to appear at court, because he doesn’t have a B+E licence, in addition, because he doesn’t have that licence, he cannot, in law, hold any insurance for that rig, yes really! 

 

He goes to court with my caravans CofC and Bailey’s brochure, both of which show the lower, non gas locker decal, weight (which puts the rig just under 3500) Will he be convicted of having no driving licence?

 If yes then what’s the point if the external decal if it has no meaning? In addition how many other rigs are being driven illegally because of that discrepancy?

 

If he is NOT convicted then the courts are clearly happy to accept the external plate details are the ones to be used DESPITE what the Type Approval Plate shows.

 

But the trouble is it’s an “absolute offence” it’s either legal or not, the courts have no room to apply common sense, only the law.

 

In reality I have a strong feeling it would never get to court UNLESS there was a fatality, at which point a court would have to decide which of the two plates applies! What if the person in court is you? Difficult eh? 

 

It’s clearly a total lash up on the part of the NCC and the caravan industry, it REALLY does need  sorting out once and for all, but clearly the will to do so isn’t there. So in the meantime we will continue to argue the matter on forums such as this! 

 

I have, as someone well versed in road traffic law, voiced my views/opinions (and that’s all they are) a number of times on the subject. So I will leave it to others to make their decisions. Remember this involves the law, common sense and practicalities do NOT come into the equation. It’s either black or it’s white, no room for grey of any shade!  

 

Andy

 

 

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9 minutes ago, Mr Plodd said:

Remember this involves the law, common sense and practicalities do NOT come into the equation. It’s either black or it’s white, no room for grey of any shade!  

 

Andy

 

 

Does that not then simplify it, surely the statutory plate rather than anything else applies?

 

Or is that too naive, assuming something to meet a statutory requirement,  rules over a trade organisations plate?

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14 minutes ago, Mr Plodd said:

 

So, going back to the scenario with my caravan and my son borrowing it, just suppose for the sake of argument, that some Oik removes the external decal whilst he is on a campsite, and when he leaves the site he is stopped by VOSA. The combined weight (according to the gas locker plate) exceeds 3500kg by 43kg. BUT the manufacturer (Bailey) designates that model as having a weight that puts the rig just UNDER 3500kg at 3497kg (actual figures for my van) 

 

Son gets summonsed to appear at court, because he doesn’t have a B+E licence, in addition, because he doesn’t have that licence, he cannot, in law, hold any insurance for that rig, yes really! 

 

He goes to court with my caravans CofC and Bailey’s brochure, both of which show the lower, non gas locker decal, weight (which puts the rig just under 3500) Will he be convicted of having no driving licence?

 If yes then what’s the point if the external decal if it has no meaning? In addition how many other rigs are being driven illegally because of that discrepancy?

 

If he is NOT convicted then the courts are clearly happy to accept the external plate details are the ones to be used DESPITE what the Type Approval Plate shows.

 

But the trouble is it’s an “absolute offence” it’s either legal or not, the courts have no room to apply common sense, only the law.

 

In reality I have a strong feeling it would never get to court UNLESS there was a fatality, at which point a court would have to decide which of the two plates applies! What if the person in court is you? Difficult eh? 

 

It’s clearly a total lash up on the part of the NCC and the caravan industry, it REALLY does need  sorting out once and for all, but clearly the will to do so isn’t there. So in the meantime we will continue to argue the matter on forums such as this! 

 

I have, as someone well versed in road traffic law, voiced my views/opinions (and that’s all they are) a number of times on the subject. So I will leave it to others to make their decisions. Remember this involves the law, common sense and practicalities do NOT come into the equation. It’s either black or it’s white, no room for grey of any shade!  

 

Andy

 

 

 

The CofC that you mention is an NCC CofC which is not a legal document. You will find that the type approval CofC will show the same MTPLM as on the statutory plate.

 

As there is no reference anywhere in legislation regarding vehicle weight limits to anything other than the statutory plate, any recognition of the label by the door as absolutely at the discretion of the court.

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But you can, if you wish, have a motorhome DOWN plated from just over, to just under 3500kg if you wish. That doesn’t alter in any way  the MTPLM that’s shown on the makers VIN plate but it DOES allow it to be driven if you don’t have a B+E licence, that’s DESPITE what the “original” VIN plate shows. I would  suggest that’s exactly what caravan makers do. So, by using the same rules, which weight do YOU say should be used for enforcement? Serious question.

 

Likewise you can have a MH’s MTPLM upgraded beyond what the makers VIN plate shows. I am referring to upgrading beyond the second stage manufacturers plate not the chassis makers VIN. (As in the plate affixed by Autotrail not Fiat) and it’s the upgraded weight plate that is used for ALL Enforcement purposes. 

 

Like I said, it really needs sorting out so it’s clear and unambiguous,  in order to avoid arguments such as this.,

 

Andy

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I'm not really sure how a law change could satisfactorily resolve the issue. If you clarify by clearly saying manufacturer's can downplate, then that's effectively what they do now, but if that plate goes missing then the higher chassis plate could be the only evidence of a weight limit. Would a court hold that a sales brochure's figure is sufficient evidence against a firmly affixed chassis makers plate?

If manufacturer's adopted the Continental practice of not downplating vans from their axles weight limits then you'd have to stop voluntary downplating in order that a court could be certain that the chassis limit was applicable. And presumably having all vans at their axle limits would reduce even further the potential vans available for B licence holders and possibly for the range of towcars as they strive to reduce weight, in order to cut fuel consumption and emissions. 

The caravan industry would be on even more of a hiding to nothing.

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Posted (edited)
1 hour ago, Mr Plodd said:

But you can, if you wish, have a motorhome DOWN plated from just over, to just under 3500kg if you wish. That doesn’t alter in any way  the MTPLM that’s shown on the makers VIN plate but it DOES allow it to be driven if you don’t have a B+E licence, that’s DESPITE what the “original” VIN plate shows. I would  suggest that’s exactly what caravan makers do. So, by using the same rules, which weight do YOU say should be used for enforcement? Serious question.

 

Likewise you can have a MH’s MTPLM upgraded beyond what the makers VIN plate shows. I am referring to upgrading beyond the second stage manufacturers plate not the chassis makers VIN. (As in the plate affixed by Autotrail not Fiat) and it’s the upgraded weight plate that is used for ALL Enforcement purposes. 

 

Like I said, it really needs sorting out so it’s clear and unambiguous,  in order to avoid arguments such as this.,

 

Andy

 

Any change to an MTPLM, whether up-plating or downplating, relative to what is shown on the existing statutory plate, will always require a new statutory plate and that can only be issued by the manufacturer. The reason for this is that any such change must be covered by the type approval documentation and the type approval number must also be displayed on the statutory plate. Type approval may cover a range of MTPLMs but the valid MTPLM must always be within that range.

In the example that you mention, the plate affixed by Autotrail obviously can't show a higher MTPLM than the one that Fiat applied unless they accept full product liability due to possible chassis and/or braking system modifications or whatever, that they may have added. The Autotrail plate will always take precedence over the Fiat plate.

 

Edited by Lutz

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Posted (edited)
1 hour ago, Steamdrivenandy said:

I'm not really sure how a law change could satisfactorily resolve the issue. If you clarify by clearly saying manufacturer's can downplate, then that's effectively what they do now, but if that plate goes missing then the higher chassis plate could be the only evidence of a weight limit. Would a court hold that a sales brochure's figure is sufficient evidence against a firmly affixed chassis makers plate?

If manufacturer's adopted the Continental practice of not downplating vans from their axles weight limits then you'd have to stop voluntary downplating in order that a court could be certain that the chassis limit was applicable. And presumably having all vans at their axle limits would reduce even further the potential vans available for B licence holders and possibly for the range of towcars as they strive to reduce weight, in order to cut fuel consumption and emissions. 

The caravan industry would be on even more of a hiding to nothing.

 

Continental manufacturers can downplate from existing axle weight limits by issuing a new statutory plate and they will do so if requested on condition that the downplated weight is covered by type approval documentation. However, it is not normal practice and would only be done at special request because it basically means that the vehicle may be fitted with a heavier duty axle than what is actually required.

 

Edited by Lutz

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5 hours ago, Lutz said:

Any change to an MTPLM, whether up-plating or downplating, relative to what is shown on the existing statutory plate, will always require a new statutory plate and that can only be issued by the manufacturer. The reason for this is that any such change must be covered by the type approval documentation and the type approval number must also be displayed on the statutory plate. Type approval may cover a range of MTPLMs but the valid MTPLM must always be within that range.

In the example that you mention, the plate affixed by Autotrail obviously can't show a higher MTPLM than the one that Fiat applied unless they accept full product liability due to possible chassis and/or braking system modifications or whatever, that they may have added. The Autotrail plate will always take precedence over the Fiat plate.

 

 

Having actually upgraded a motorhome in the past I speak from a position of first hand knowledge.

My Autotrail motorhome was upgraded from BOTH the original Mercedes plate and the (higher weight) Autotrail plate. The new plate was not issued by either Merecedes or Autotrail but by a company called SV Tech It is they who issued me with, what was in effect a third VIN plate. If you click on the link all will be explained. As an aside if you DO ever have a MH upgraded the “new” plate, as issued by SV Tech and the like, must not obscure ANY of the previous ones!!

 

The plate  affixed by the “second stage” manufacturer  (Autotrail)  did indeed show a higher MAM than the Mercedes one did. And the SV Tech one was higher still. It’s  pretty common practice with motorhomes. They are often type approved to beyond the second stage manufactures MTPLM.

 

So if SV Tech can issue higher (and lower) MTPLM plates for various vehicles I can see no reason whatsoever that the original manufacturer of a caravan cannot do likewise, which is in effect EXACTLY what they do.

 

They get a certain range “Type Approved” to one weight and then send them out of the factory with a slightly lower one. Just because a vehicle is type approved to say 5 tonnes doesn’t mean it HAS to be plated at that weight, the makers can, and frequently do, stipulate a lower one. If you go back a few posts I explain why some 7500+kg HGV’s are downplayed in order to enable B+E licence holders to drive them. 

 

I am aware of at least one Motorhome makers whose vehicles  leave the factory plated at 3650kg. HOWEVER you can order one with a lower MTPLM of 3500kg in order to negate the need for a B+E licence. The ONLY difference is the plate. However the available payload is of course reduced by that 150kg.

Again that’s exactly the procedure adopted by caravan makers. Type approved to 1450, plated at 1397 (which is the case with my Platinum, which I have had upgraded) 

 

Andy

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14 minutes ago, Mr Plodd said:

 

Having actually upgraded a motorhome in the past I speak from a position of first hand knowledge.

My Autotrail motorhome was upgraded from BOTH the original Mercedes plate and the (higher weight) Autotrail plate. The new plate was not issued by either Merecedes or Autotrail but by a company called SV Tech It is they who issued me with, what was in effect a third VIN plate. If you click on the link all will be explained. As an aside if you DO ever have a MH upgraded the “new” plate, as issued by SV Tech and the like, must not obscure ANY of the previous ones!!

 

The plate  affixed by the “second stage” manufacturer  (Autotrail)  did indeed show a higher MAM than the Mercedes one did. And the SV Tech one was higher still. It’s  pretty common practice with motorhomes. They are often type approved to beyond the second stage manufactures MTPLM.

 

So if SV Tech can issue higher (and lower) MTPLM plates for various vehicles I can see no reason whatsoever that the original manufacturer of a caravan cannot do likewise, which is in effect EXACTLY what they do.

 

They get a certain range “Type Approved” to one weight and then send them out of the factory with a slightly lower one. Just because a vehicle is type approved to say 5 tonnes doesn’t mean it HAS to be plated at that weight, the makers can, and frequently do, stipulate a lower one. If you go back a few posts I explain why some 7500+kg HGV’s are downplayed in order to enable B+E licence holders to drive them. 

 

I am aware of at least one Motorhome makers whose vehicles  leave the factory plated at 3650kg. HOWEVER you can order one with a lower MTPLM of 3500kg in order to negate the need for a B+E licence. The ONLY difference is the plate. However the available payload is of course reduced by that 150kg.

Again that’s exactly the procedure adopted by caravan makers. Type approved to 1450, plated at 1397 (which is the case with my Platinum, which I have had upgraded) 

 

Andy

SV Tech hold IVA model reports for vehicles that they fit their equipment to. This allows them to fit a Statutory plate as if they were a Second or Third Stage converter on the basis of the report compiled from the vehicle they originally submit for approval. 

They of course not seen as a multi stage converter as this is not applicable to IVA. They can only offer this for vehicles that are specific to the Type Variant and Version  covered by the report. As such as models change they will be continually retesting and adding to the report.

It's sort of a half way house to Series production type approval.

I'm my view it's the way caravan dealers should be treated aswell when fitting movers etc , but as O1 and O2 trailers are not registered and rarely issued with C of Cs in the UK its overlooked.

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Well I did ask a lot of salesmen what upgrades were available across most makes.  Some were very good. Some totally lost. No change there then

 

Whilst I was doing that SWMBO. took a shine to the Alecanto Estoril.  She’s got o wait till next year though as they have sold that many.  

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We had the free weight upgrade at the Lawns show, Interesting to find out, 2020 Coachman vans no longer have a weight certificate, to go with the wall sticker, the certificate that comes with the van does not even refer to the VIN, just a certificate number refering to the build approval of the NCC. Not sure if that is the case with other manufacturers.

 

Also, when we collected our new van, I was talking to the manager, who also said no documents are handed over to purchasers of used vans as this contains personal details of original buyer and is not allowed under the new rules of data protection. All service details are held on the dealers and manufacturers databases. 

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2 hours ago, kiaboy said:

We had the free weight upgrade at the Lawns show, Interesting to find out, 2020 Coachman vans no longer have a weight certificate, to go with the wall sticker, the certificate that comes with the van does not even refer to the VIN, just a certificate number refering to the build approval of the NCC. Not sure if that is the case with other manufacturers.

 

 

If the certificate doesn't refer to the VIN it's not worth the paper that it's printed on because it doesn't comply with the regulations. Not only must it refer to the VIN but also to the type approval number to make it a document of any value.

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