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Tow Weights clarification


Flatcoat888
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30 minutes ago, Towtug said:

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

 

As I said. No interest to UK consumers, only of interest to UK manufacturers wishing to sell products to EU consumers!

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1 hour ago, Towtug said:

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

 

That's hardly a workable solution. I can't see dealers getting involved in any type approval process. Anyway, what, in principle, is the difference between a dealer fitting, say, an air conditioning unit or the owner doing it himself?

1 hour ago, Legal Eagle said:

As I said. No interest to UK consumers, only of interest to UK manufacturers wishing to sell products to EU consumers!

 

It would be to NI consumers!

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3 hours ago, Lutz said:

......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?

 

That is a red herring, it is an accurate initial starting weight that most of us are referring to here.

 

How accurately a purchaser weighs a caravans contents is up to them but for those of us with a modicum of common sense we would ensure that all items were at least accounted for and weighed accordingly.

 

 

Stay safe - Griff.  :ph34r:

Wheels at the front Green Oval Towing Machine

Wheels at the back Bessacarr 845

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5 hours ago, Griff said:

 

That is a red herring, it is an accurate initial starting weight that most of us are referring to here.

 

How accurately a purchaser weighs a caravans contents is up to them but for those of us with a modicum of common sense we would ensure that all items were at least accounted for and weighed accordingly.

 

 

 

How accurate would you expect an ex-works unladen weight figure to be? I don't think that any manufacturer would be willing to go along with any requirement to specify a figure with a tighter tolerance than what is already allowed under existing trading standards.

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So how much tolerance are you allowed on the MTPLM or if pulled by the boys in blue? How much tolerance is allowed for a car Mass in Service weight on the V5? 

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5 minutes ago, Flatcoat888 said:

So how much tolerance are you allowed on the MTPLM or if pulled by the boys in blue? How much tolerance is allowed for a car Mass in Service weight on the V5? 


I’ve no idea what the calibration tolerance on their equipment is. Beyond that it’s a matter of discretion.

My understanding is that trading standards allow a 5% tolerance, and that would presumably include Mass in Service, but I may be wrong.

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3 hours ago, Lutz said:

 

How accurate would you expect an ex-works unladen weight figure to be? I don't think that any manufacturer would be willing to go along with any requirement to specify a figure with a tighter tolerance than what is already allowed under existing trading standards.

 

Not suggesting tighter tolerances at all and willingness would not have any bearing on the matter should it become an industry requirement.

 

It would be down to the manufacturer to specify a tolerance in much the same way that if VOSA or the purchaser were to use a weighbridge a tolerance would be provided.

 

Many manufacturing companies are required to provide such certificated  ex works toleranced product weights by their insurers to cover third party lifting information.

 

Not difficult at all, will leave it there.

 

 

 

Stay safe - Griff.  :ph34r:

Wheels at the front Green Oval Towing Machine

Wheels at the back Bessacarr 845

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A tolerance on the Mass in Service figure is largely irrelevant to the consumer as it doesn’t claim to reflect the actual weight of the vehicle (caravan) in question, even though this may be a widespread belief.

Edited by Lutz
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How successful would I be in claiming the same 5% tolerance if told I was over the MTPLM by 70kg, or just under 5%? Or are the manufacturers allowed a tolerance not permitted for the public and in effect resulting in a caravanner being prosecuted through the application of different less tolerant standards? 

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23 minutes ago, Flatcoat888 said:

How successful would I be in claiming the same 5% tolerance if told I was over the MTPLM by 70kg, or just under 5%? Or are the manufacturers allowed a tolerance not permitted for the public and in effect resulting in a caravanner being prosecuted through the application of different less tolerant standards? 

 

The 5% tolerance on what figure? Presumably you would want it on what the manufacturer claims the actual weight would be, but unless you are in possession of the type approval certificate, which you probably aren't, you wouldn't know what the nominal unladen weight is.

However, if you mean the MTPLM then you are at the mercy of the officer-in-charge unless you are able to gain access to the calibration report for the scales that he happens to be using.

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I'm not sure how much use an accurate ex-works weight would be to the average caravanner because I doubt that the figure in question would ever be replicated in real life. 

 

Bits and pieces added or taken away, the moisture level in the structure varying with the atmosphere on particular days etc would all militate against that happening. When a skin of paint on an Eriba Touring can add 15kg, then the difference between a dry and a wet day could add or subtract a fair bit as the insulation and upholstery absorbs or dries out.

 

What's really needed is a minimum payload formula such that your normal, average caravanner, who doesn't micro manage their loading, can do so without fear of going overloaded. It means a 2 berth van having, say, 250kg as standard and a 4 berth 350kg etc. That would mean the 2 berth Bailey Pheonix 420 having a 1300kg MTPLM instead of the current 1146kg. A 4 berth Unicorn Cadiz starting around 1800kg MTPLM, rather than it's current 1600kg.

 

I'm not sure how such a sensible and freeing change would affect sales, especially to those with a 3500kg rig limit but they'd remove risk and worry for an awful lot of caravanners and potential caravanners.

I've got nothing to do on this hot afternoon

but to settle down and write you a line.

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Posted (edited)

I agree with Steamdriven to some extent but why not have a certified maximum MIRO weight for each caravan? That would in turn provide a minimum payload. Instead of looking constantly for excuses why manufacturers do what they do there needs to be pressure brought by threat of legislation to change. However I will not hold my breath on the clubs leading that process…… if I ever win big on the lottery I intend taking on the caravan industry either by challenging via a consumer/user group or setting up a disrupter competitor company. 
 

in the meantime unless you weigh your caravan at the start of each journey there is no certainty.

Edited by Flatcoat888
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28 minutes ago, Flatcoat888 said:

I agree with Steamdriven to some extent but why not have a certified maximum MIRO weight for each caravan? That would in turn provide a minimum payload. Instead of looking constantly for excuses why manufacturers do what they do there needs to be pressure brought by threat of legislation to change. However I will not hold my breath on the clubs leading that process…… if I ever win big on the lottery I intend taking on the caravan industry either by challenging via a consumer/user group or setting up a disrupter competitor company. 
 

in the meantime unless you weigh your caravan at the start of each journey there is no certainty.

 

There is no such thing as a maximum MIRO because  the certified MIRO is only applicable to the one caravan that was submitted for type approval. Anything else is not a MIRO at all, but an unladen (or actual) weight, and the latter is already documented under Item 13.2 in the type approval document.

Weighing the caravan at the start of each journey is the only 100% reliable method although it is going over the top a bit unless one loads it differently each time. Under normal conditions, where one packs the caravan almost identically each time, it is unlikely for the weight of the caravan will vary by much more than a handful of kilos. If those handful of kilos are going to worry you, you've chosen the wrong caravan in the first place.

As a first step it would be worthwhile demanding a copy of the type approval certificate which documents both the MIRO and the actual weight.

Edited by Lutz
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My point is IF there was a maximum MIRO it would minimise the problem. 

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There is a lot of talk here about the manufacturer providing a certified MIRO for each and every caravan. They are only required by law to put on a plate stating the maximum weight permitted and the maximum axle load. No amount of bluster and/or arguments by keyboard warriors will make them weigh each and every van in it's 'running order' to provide a certificate to the purchaser

 

A ready solution is  to take your own caravan in what you personally consider to be its 'running order' to a weighbridge and have it weighed. That way you know exactly what you have to play with when adding your personal possessions to take it up towards the MTPLM.

 

After all, if a weight offence is detected in a check, it is the driver who may be prosecuted, not the manufacturer.

 

Also, if a weight offence is detected, any decision to prosecute lies with the prosecution authorities who will take into account their own guidelines re percentage overweight for prosecution limits. It is not for the driver to 'claim' an allowance or tolerance, but that may be used in court as their mitigation if they so wish.

 

The offence is using a vehicle on a road when the plated weight is exceeded, not when the plated weight give or take a tolerance is exceeded.

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There seems to be a lot of leeway being given to the manufacturer here. While they don't legally have to provide a MIRO they do use this figure to give the payload in all of their advertising for the model. While obviously any non-standard add-ons would need to be added, I think it's reasonable to assume that the payload available ought to be within an error margin of what the manufacturer is advertising it as having.

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54 minutes ago, Flatcoat888 said:

My point is IF there was a maximum MIRO it would minimise the problem. 

 

You mean if there was a maximum unladen weight. MIRO is by definition a minimum.

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I've had my last 4 caravans on a weighbridge, easy for me as I live within a few miles of a public weighbridge and if I call in at work we have seven.

 

But, I've never had the the need to check MIRO. 

 

Always bought a vehicle that will deal with the MTPLM and then checked with the weighbridge I'm below that with our usual gear.

 

Dealer fit options and movers I can see being a problem but do they actually leave the factory with the MIRO significantly wrong? Has anyone checked?

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

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47 minutes ago, logiclee said:

Dealer fit options and movers I can see being a problem but do they actually leave the factory with the MIRO significantly wrong? Has anyone checked?

 

You can't check the MIRO because that's the weight of the caravan that the manufacturer submitted for type approval and you won't have access to it.

One has got to be clear in one's mind that MIRO is not the unladen weight of your particular caravan.

Edited by Lutz
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 But in practice that is how it is conveyed to the average (99% of) buyer! I am not criticising your clarification of the legal interpretation but you have to agree it is wholly unsatisfactory. 

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48 minutes ago, logiclee said:

Dealer fit options and movers I can see being a problem but do they actually leave the factory with the MIRO significantly wrong? Has anyone checked?

 I've been following this thread and have just had a revelation. When we picked up our present 'van in 2013, 2011 Xplore 302, we took it to a weighbridge and found that it was over the M.I.R.O. figure in the handbook, by around 40 Kg. I just realised that the extra weight is probably because it had the Elddis SE pack fitted (alloy wheels, spare wheel and carrier and a door flyscreen). Only had it 8 years, I am a bit slow sometimes. :lol:

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10 minutes ago, Flatcoat888 said:

 But in practice that is how it is conveyed to the average (99% of) buyer! I am not criticising your clarification of the legal interpretation but you have to agree it is wholly unsatisfactory. 

 

I agree, the situation is unsatisfactory because too many sources either misinterpret MIRO themselves or they convey an incorrect interpretation. If one side, like the manufacturer, sticks to the true definition of MIRO and the other, the owner, thinks that it's the ex-works weight of his particular caravan, that's bound to lead to confusion. It would be best to dissociate one's self from MIRO altogether and introduce a new term that everyone can understand and adhere to. In the type approval process they seem to have appreciated the problem and added the term "actual mass" to differentiate it from MIRO. The trouble is that, in the UK, the certificate that documents actual mass is not normally passed on to the consumer. On the Continent, where caravans are registered, it is essential for the owner to have the type approval certificate because without it, it is impossible to register the caravan.

We have a similar situation with cars, where there is often confusion, even by manufacturers, between kerbweight and MIRO (Mass in Service).

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1 hour ago, Lutz said:

 

You can't check the MIRO because that's the weight of the caravan that the manufacturer submitted for type approval and you won't have access to it.

 

 

My point is I could check the unladen weight of the caravan against what is quoted on the caravans stickered MIRO.

 

This would then give me my true payload allowance so not to exceed MTPLM 

 

I'm not really interested in CoC, type approval or which regulation is in force but not exceeding MTPLM is critical.  

Edited by logiclee

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

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31 minutes ago, Flat_at said:

 I've been following this thread and have just had a revelation. When we picked up our present 'van in 2013, 2011 Xplore 302, we took it to a weighbridge and found that it was over the M.I.R.O. figure in the handbook, by around 40 Kg. I just realised that the extra weight is probably because it had the Elddis SE pack fitted (alloy wheels, spare wheel and carrier and a door flyscreen). Only had it 8 years, I am a bit slow sometimes. :lol:

 

Elddis don't make the 302 but I've just checked the options page for the 304 and the way its worded could be confusing. It says something like 'dealer fitted options can use up payload', which is fair enough, but I believe the SE Pack is factory fitted which, by the inference of their own words, suggests it doesn't use up payload. Obviously if the published weight is for a poverty spec. van then anything like the SE Pack has to use up payload, these things have to weigh something but the wording isn't as clear as it could be.

I've got nothing to do on this hot afternoon

but to settle down and write you a line.

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