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Tow Weights clarification


Flatcoat888
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3 hours ago, Lutz said:

 

Indeed, but as it's not a statutory plate it has no documentary value.

 

I feel that the manufacturers should be obliged to inform the customer that a quoted MIRO does not necessarily correspond to the actual unladen weight of the caravan in question. If they want to let the customer know the actual weight as the caravan came off the production line, they shouldn't be calling it MIRO, but actual unladen weight.

 

So do we take the MTPLM, the tyre pressures and the wheel bolt torques with a pinch of salt too, because if you can't rely on one piece of information being correct then you have to be suspicious with regards to anything else on the plate.

 

 

 

Jaguar E-Pace 180D HSE R Dynamic - 2008 Swift Conqueror 540

 

"Unless otherwise stated, my posts will be my personal thoughts and have the same standing as any other member of Caravan Talk"

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25 minutes ago, Griff said:

Without specific weights for each of our caravans as they leave the production line we have no idea where we are short of taking them to a weigh bridge.

 

Would it be a big deal for the manufacturers to do the weighing?

 

 

 

Actually, manufacturers do have to state the actual weight of each particular caravan, even if it may only be a calculated value, in the type approval document. It is shown there under Item 13.2. The trouble is that the document is seldom passed on to the owner.

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23 minutes ago, Steven said:

 

So do we take the MTPLM, the tyre pressures and the wheel bolt torques with a pinch of salt too, because if you can't rely on one piece of information being correct then you have to be suspicious with regards to anything else on the plate.

 

I only stated that the MIRO is displayed for customer information purposes. By saying that it has no documentary value I only wanted to point out that it may be difficult to use as evidence in a court of law because it is not legally required on the statutory plate. Notwithstanding that, of course all details on that label should be correct.

When you mention the MTPLM, the value shown on the statutory plate is definitive, whatever any label by the door says, because that it specifically referenced in legislation. However, the DVSA have indicated that, subject to discretion, a lower MTPLM shown on the door label would normally be accepted, although final judgment would need to be established in a court of law.

Edited by Lutz
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So MTPLM figure is legal, MIRO isn’t and just effectively a guess, yet both on the same plate!! Oh I would love to see a lawyer make a mockery of that in court. 

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7 minutes ago, Flatcoat888 said:

So MTPLM figure is legal, MIRO isn’t and just effectively a guess, yet both on the same plate!! Oh I would love to see a lawyer make a mockery of that in court. 

 

The MIRO is just as legal as the MTPLM, but one has to be fully aware of what the MIRO represents, that it is not the actual weight of the caravan in question. It is therefore by no means a guess. The actual weight of the caravan is documented elsewhere - in the type approval document.

MIRO is not a plated value, neither are tyre pressure, wheel nuts torques, etc. They are displayed for customer information only.

Edited by Lutz
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26 minutes ago, Lutz said:

 

Actually, manufacturers do have to state the actual weight of each particular caravan, even if it may only be a calculated value, 

 

How can an actual weight be a calculated weight?

 

The two methods fly in the face of each other.

 

The only way the actual weight of the likes of a caravan can be achieved is by weighing.

 

VOSA manage it without calculations.

Stay safe - Griff.  :ph34r:

Wheels at the front Green Oval Towing Machine

Wheels at the back Bessacarr 845

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23 minutes ago, Griff said:

 

How can an actual weight be a calculated weight?

 

The two methods fly in the face of each other.

 

The only way the actual weight of the likes of a caravan can be achieved is by weighing.

 

VOSA manage it without calculations.

 

The weight of each component can be calculated. Knowing which components have gone into the final product, the actual weight is arrived at by calculating the sum of the weight of all respective components in the bill of material. If individual components are changed, added or deleted in the course of time, so will the calculated actual weight change. It saves having to carry out an additional operation at the end of the production line to weigh the whole thing because the weights of all components are already stored on a database. It also enables the manufacturer to establish the actual weight of a caravan before it is even built.

Of course, that doesn't prevent a manufacturer from physically weighing the final product if he wants to, but he doesn't have to in order to satisfy the requirement of stating the actual weight.

Edited by Lutz
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So in theory you could have an actual MIRO higher than the MTPLM…. I appreciate Lutz you are clarifying the legal position but it cannot remotely be deemed satisfactory. 

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3 minutes ago, Flatcoat888 said:

So in theory you could have an actual MIRO higher than the MTPLM.

 

I think it would be safe to assume that such a case, if it were ever to happen, would become apparent before the caravan left the factory. One could even devise an automatic control system in the software whereby the departments involved are warned ahead of the build.

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Surely the MIRO is established via the CAD system that the manufacturer uses, which has the average weight of all the elements in the van built into the software. Having arrived at MIRO they they add the NCC minimum payload formula figure and that gives them the MTPLM.  Once that's established they then select the next highest axle weight and adjust the MIRO and MTPLM if the relevant axle adds any further weight.

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but to settle down and write you a line.

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1 minute ago, Steamdrivenandy said:

Surely the MIRO is established via the CAD system that the manufacturer uses, which has the average weight of all the elements in the van built into the software. Having arrived at MIRO they they add the NCC minimum payload formula figure and that gives them the MTPLM.  Once that's established they then select the next highest axle weight and adjust the MIRO and MTPLM if the relevant axle adds any further weight.

 

I think it is fair to assume that UK manufacturers work that way, yes. It is unfortunately that they go by what the NCC declares as a minimum payload without taking market demand into consideration.

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The NCC isn't some disconnected authoritarian body that hands out rules that  are at disconnect from the industry. It is the industry's trade association and is financed by the industry. I bet the senior NCC staff and committees are full of industry secondees and if something wasn't seen as being in the industry's interests it would soon disappear. Not sure why they won't amend the minimum formula but it's pretty obvious that at least the majority of the UK industry are happy for it to continue in its present form.

I've got nothing to do on this hot afternoon

but to settle down and write you a line.

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3 hours ago, Lutz said:

 

Actually, manufacturers do have to state the actual weight of each particular caravan, even if it may only be a calculated value, in the type approval document. It is shown there under Item 13.2. The trouble is that the document is seldom passed on to the owner.

 

I have had 3 brand new caravan's and have never see any such document, I wonder how many members reading and posting in this topic have either seen, or had one presented when taking delivery of new caravan?

Jaguar E-Pace 180D HSE R Dynamic - 2008 Swift Conqueror 540

 

"Unless otherwise stated, my posts will be my personal thoughts and have the same standing as any other member of Caravan Talk"

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14 minutes ago, Steven said:

 

I have had 3 brand new caravan's and have never see any such document, I wonder how many members reading and posting in this topic have either seen, or had one presented when taking delivery of new caravan?

Only ever had the Certificate of Conformity included in the owner's pack (and the replacement C of C following MTPLM upgrades). Not being in the EU, EC Type Approval documentation is really of little interest to UK consumers now! 😉

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Same here. 5 new vans since 1993, no certiificate.

 

As an aside, I tried to establish the actual weight of my current Tiguan SEL, I asked VW UK to provide one, which they did - in German - and 13.2 is quite a bit higher than the 'mass in service' on the V5

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I've never seen a 'real' c of c for a caravan, just the NCC's certificate, which isn't a c of c. As I've posted before I did get one with our new Scala back in June 2020, bought from Skoda, Darlington aka Bristol Street Motors.

I've got nothing to do on this hot afternoon

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3 hours ago, Lutz said:

 

The weight of each component can be calculated...

 

Calculating the weight of each component, of which there are a great many,  would lead to further inaccuracies.

Probably sufficient for a small Halfords trailer.

 

Weighing each component would be closer but only actually weighing the final assembly and providing that weight along with the inclusions and exclusions would give something positive to work with before then weighing additional items the purchaser would wish to add from that point.

 

 

Stay safe - Griff.  :ph34r:

Wheels at the front Green Oval Towing Machine

Wheels at the back Bessacarr 845

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Just now, Griff said:

 

Calculating the weight of each component, of which there are a great many,  would lead to further inaccuracies.

Probably sufficient for a small Halfords trailer.

 

Weighing each component would be closer but only actually weighing the final assembly and providing that weight along with the inclusions and exclusions would give something positive to work with before then weighing additional items the purchaser would wish to add from that point.

 

 

 

Weighing each component is no more accurate because one would never know whether the component weighed was manufactured at top or bottom tolerance. Calculated weights are always based on nominal dimensions. For example, car bodies coming out of the paint shop in our factory showed weight variances of up to 15kg although all material thicknesses were within tolerance.

45 minutes ago, Lagerorwine said:

Same here. 5 new vans since 1993, no certiificate.

 

As an aside, I tried to establish the actual weight of my current Tiguan SEL, I asked VW UK to provide one, which they did - in German - and 13.2 is quite a bit higher than the 'mass in service' on the V5

 

The CofC for my BMW quotes a mass in running order (mass in service) of 1895kg and an actual mass of 1980kg.

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19 minutes ago, Lutz said:

The CofC for my BMW quotes a mass in running order (mass in service) of 1895kg and an actual mass of 1980kg.


My BMW quoted Mass in Service was 1695kg, the day it arrived I took it to the weigh-bridge and it came off at 1740kg

Jaguar E-Pace 180D HSE R Dynamic - 2008 Swift Conqueror 540

 

"Unless otherwise stated, my posts will be my personal thoughts and have the same standing as any other member of Caravan Talk"

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15 minutes ago, Lutz said:

 

Weighing each component is no more accurate because one would never know whether the component weighed was manufactured at top or bottom tolerance. Calculated weights are always based on nominal dimensions. For example, car bodies coming out of the paint shop in our factory showed weight variances of up to 15kg although all material thicknesses were within tolerance.

 

And so with the multiplicity of components in a typical caravan build, as I say not definatively accurate enough 

 

The only way for a purchasers purpose, i.e an accurate base weight to add logged and weighed 'stuff' to would be actually weigh the unit before shipment.

 

Any other method not fit for this purpose.

 

 

Stay safe - Griff.  :ph34r:

Wheels at the front Green Oval Towing Machine

Wheels at the back Bessacarr 845

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1 hour ago, Lagerorwine said:

Same here. 5 new vans since 1993, no certiificate.

 

As an aside, I tried to establish the actual weight of my current Tiguan SEL, I asked VW UK to provide one, which they did - in German - and 13.2 is quite a bit higher than the 'mass in service' on the V5

 

VAG dealers will usually declare VAG's "Minimum kerbweight with driver" for the V5 Mass in service.

 

For my Yeti the Mass in Service is 1585kg the same as the brochure.  CoC is 1660kg.

Yeti 2.0TDi EU6 150 DSG 4X4 L&K, Octavia TSi Manual, Fabia TSi DSG, Swift Challenger.

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1 hour ago, Legal Eagle said:

Only ever had the Certificate of Conformity included in the owner's pack (and the replacement C of C following MTPLM upgrades). Not being in the EU, EC Type Approval documentation is really of little interest to UK consumers now! 😉

It's of just as much interest as it was previously,  as the EU type approval was written across into UK law. Manufacturers now have to apply for EU type approval if they wish to sell in EU27 countries, and produce a EU Certificate of Conformity, this is not valid in the UK except Northern ireland.  At the same time they will shortly have to duplicate that approval with a GBTA (Great Britain Type approval) and produce a GB Certificate of Conformity,  this is only valid in England, Wales and Scotland and Not Northern Ireland. 

To cover Northern Ireland without a EU approval the manufacturer has to apply for a UKNI  approval and issue the appropriate Certificate of Conformity.

 

At the moment because caravans aren't registered in the UK we are still working under EU provisions but that ends on Dec31st 2021 with a transitional period to Dec 31st 2022.

So during the next year all trailer manufacturers will need to duplicate their approvals if they are to continue selling in both EU27 and GB

 

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30 minutes ago, Griff said:

 

And so with the multiplicity of components in a typical caravan build, as I say not definatively accurate enough 

 

The only way for a purchasers purpose, i.e an accurate base weight to add logged and weighed 'stuff' to would be actually weigh the unit before shipment.

 

Any other method not fit for this purpose.

 

 

I couldn't agree more Griff!
Since the owner is likely to be subject to more & more road-side inspections as time goes on (there is a big increase expected this year!) why should we be subject to 'guestimated' weights & possibly suffer prosecution because of it?

There is no real excuse for not providing the actual weight of the actual 'van purchased.  A quoted 5% tolerance is nothing but a joke, it is pure indifference on the part of the manufacturers, which is their default mode. They wont change until they are pushed to by law.
 Let's not forget that the average, much abused, weighbridge is only claimed to be  accurate within 5% & very  probably is worse outside calibration time. At least the manufacturers could calibrate theirs frequently & it (hopefully!) would not get the miss-use that commercial ones endure. I have little confidence in commercial weigh-bridges as they have to weigh 20 or even 30 ton wagons one minute & then we expect them to weigh 1 1/2 ton 'vans with accuracy! Adding all the possible tolerances up becomes utterly frightening!

One thing is for sure, potentially, we are being hung out to dry!

 

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But as far as roadside weight checks are concerned, MIRO is totally irrelevant. How do you know whether the items that you've put on board are weighed accurately as well or maybe you've even overlooked something that wasn't weighed before it went into the caravan?

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The actual mass is relatively easy for a manufacturer to account for without weighing each van. (I have to say though that all the main manufacturers I've worked with have had the ability to weigh Van's and regularly did so on an audit sample basis required by the control plans in their COP.

 

The actual weight can be calculated on the basis of the sum of the equipment fitted . The equipment fitted is dictated by the Type, Variant and Version. So fitting various equipment options changes the TVV code. The TVV code then dictates the mass.

 

In my view greater problems arise when dealers fit optional equipment which eats into the payload without then upgrading to replace it.

 

Dealers should be considered as Second Stage manufacturers Unless those options are fitted by the manufacturer where their effect can be properly controlled.

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