Caravan gross weight.

[Simple_Life]

It is not the same issue.

EU plate for the vehicle and it's vehicle components. This is one regulation.

Manufacturer's plate for the use of that vehicle on roads, this is a UK Department of Transport edict, following the still in force C&U regs.

So we can see, former covers the Construction and the later the use.

Two different issues.

 

[Lutz]

It is not the same issue.

EU plate for the vehicle and it's vehicle components. This is one regulation.

Manufacturer's plate for the use of that vehicle on roads, this is a UK Department of Transport edict, following the still in force C&U regs.

So we can see, former covers the Construction and the later the use.

Two different issues.

I cannot see a conflict between the two issues that cannot be resolved with just one plate.

Both Construction and Use Regulations and Vehicle Approval Regulations reference the same EU directive concerning the MTPLM and MTPLM is only defined in that same EU directive, so there can only be one MTPLM.

 

[Simple_Life]

It can only be resolved by one plate if all purchasers of caravans want that.

But I would suggest the majority are happy with buying a caravan that when loaded their car can tow.

I suggest you give thought to my answers above.

The other point on the other thread that hasn't been picked up, if you go Bailey Sub section there is a plate that shows Bailey type approved in Luxembourg, and the plate is showing total MTPLM transferred to road via axle 0,1,2

Enjoy

 

[Lutz]

It can only be resolved by one plate if all purchasers of caravans want that.

But I would suggest the majority are happy with buying a caravan that when loaded their car can tow.

I suggest you give thought to my answers above.

The other point on the other thread that hasn't been picked up, if you go Bailey Sub section there is a plate that shows Bailey type approved in Luxembourg, and the plate is showing total MTPLM transferred to road via axle 0,1,2

Enjoy

It's not up to the purchaser to decide what the MTPLM shall be. The manufacturer must document the figure and as I said, there can only be one MTPLM as defined in the relevant EU directive. Anything else isn't an MTPLM so it must not be documented as such.

What is basically wrong with the MTPLM being the sum of all the maximum axle loads? I agree, it's a bit irrational because it would require the owner to make full use of all maximum axle loads in order to be able to load the caravan to its MTPLM, but in theory there can be no objection in principle to plating that way.

 

[Simple_Life]

It can only be resolved by one plate if all purchasers of caravans want that.

But I would suggest the majority are happy with buying a caravan that when loaded their car can tow.

I suggest you give thought to my answers above.

The other point on the other thread that hasn't been picked up, if you go Bailey Sub section there is a plate that shows Bailey type approved in Luxembourg, and the plate is showing total MTPLM transferred to road via axle 0,1,2

Enjoy

It's not up to the purchaser to decide what the MTPLM shall be. The manufacturer must document the figure and as I said, there can only be one MTPLM as defined in the relevant EU directive. Anything else isn't an MTPLM so it must not be documented as such.

What is basically wrong with the MTPLM being the sum of all the maximum axle loads? I agree, it's a bit irrational because it would require the owner to make full use of all maximum axle loads in order to be able to load the caravan to its MTPLM, but in theory there can be no objection in principle to plating that way.

You mis understand on both points

I have proven there can be two MTPLM within the UK, custom and practice shows the UK operate this way, and I have given you reason as to why, that is Dot.
There is no doubt.
As for why the manufacturers choose a lower MTPLM on the manufacturers plate I suggest it's sales led.

As for Bailey Type approval plate, it does not show maximum plated loads of axle 0,1,2 but how that load is transferred to the ground, completely different to how others do it.
For example

Swift
Axle 0, 100kg
Axle 1, 1000kg
Axle 2, 1000kg.
(From an actual plate)

Bailey
Axle 0, 94kg
Axle1, 853kg
Axle2, 853kg
(From an actual plate)

Both caravans had type approval to 1800kg.

Both gained type approval in Luxenbourgh

 

[otherclive]

It can only be resolved by one plate if all purchasers of caravans want that.

But I would suggest the majority are happy with buying a caravan that when loaded their car can tow.

I suggest you give thought to my answers above.

The other point on the other thread that hasn't been picked up, if you go Bailey Sub section there is a plate that shows Bailey type approved in Luxembourg, and the plate is showing total MTPLM transferred to road via axle 0,1,2

Enjoy

It's not up to the purchaser to decide what the MTPLM shall be. The manufacturer must document the figure and as I said, there can only be one MTPLM as defined in the relevant EU directive. Anything else isn't an MTPLM so it must not be documented as such.

What is basically wrong with the MTPLM being the sum of all the maximum axle loads? I agree, it's a bit irrational because it would require the owner to make full use of all maximum axle loads in order to be able to load the caravan to its MTPLM, but in theory there can be no objection in principle to plating that way.

You mis understand on both points

I have proven there can be two MTPLM within the UK, custom and practice shows the UK operate this way, and I have given you reason as to why, that is Dot.
There is no doubt.
As for why the manufacturers choose a lower MTPLM on the manufacturers plate I suggest it's sales led.

As for Bailey Type approval plate, it does not show maximum plated loads of axle 0,1,2 but how that load is transferred to the ground, completely different to how others do it.
For example

Swift
Axle 0, 100kg
Axle 1, 1000kg
Axle 2, 1000kg.
(From an actual plate)

Bailey
Axle 0, 94kg
Axle1, 853kg
Axle2, 853kg
(From an actual plate)

Both caravans had type approval to 1800kg.

So are you saying the Swift could in theory be loaded to 2200kg ?

 

[Lutz]

You mis understand on both points

I have proven there can be two MTPLM within the UK, custom and practice shows the UK operate this way, and I have given you reason as to why, that is Dot.
There is no doubt.
As for why the manufacturers choose a lower MTPLM on the manufacturers plate I suggest it's sales led.

As for Bailey Type approval plate, it does not show maximum plated loads of axle 0,1,2 but how that load is transferred to the ground, completely different to how others do it.
For example

Swift
Axle 0, 100kg
Axle 1, 1000kg
Axle 2, 1000kg.
(From an actual plate)

Bailey
Axle 0, 94kg
Axle1, 853kg
Axle2, 853kg
(From an actual plate)

Both caravans had type approval to 1800kg.

You have not proven at all that there can be two MTPLMs. You have only confirmed that two MTPLMs are in use, but not that they are used correctly and in line with the requirements as laid down in the respective EU Directive, applicable to both Construction and Use and Vehicle Approval regulations..

Of course the lower MTPLM is sales led, but then the same lower MTPLM should also appear on the statutory plate.

The type approval plate MUST always quote the maximum values allowable, hence for the Bailey case in question, the maximum allowable axle load is 853kg for each axle and the maximum allowable noseweight is 94kg. If that is not what Bailey meant, they have documented the type approval plate wrongly.

 

[Simple_Life]

You mis understand on both points

I have proven there can be two MTPLM within the UK, custom and practice shows the UK operate this way, and I have given you reason as to why, that is Dot.
There is no doubt.
As for why the manufacturers choose a lower MTPLM on the manufacturers plate I suggest it's sales led.

As for Bailey Type approval plate, it does not show maximum plated loads of axle 0,1,2 but how that load is transferred to the ground, completely different to how others do it.
For example

Swift
Axle 0, 100kg
Axle 1, 1000kg
Axle 2, 1000kg.
(From an actual plate)

Bailey
Axle 0, 94kg
Axle1, 853kg
Axle2, 853kg
(From an actual plate)

Both caravans had type approval to 1800kg.

You have not proven at all that there can be two MTPLMs. You have only confirmed that two MTPLMs are in use, but not that they are used correctly and in line with the requirements as laid down in the respective EU Directive, applicable to both Construction and Use and Vehicle Approval regulations..

Of course the lower MTPLM is sales led, but then the same lower MTPLM should also appear on the statutory plate.

The type approval plate MUST always quote the maximum values allowable, hence for the Bailey case in question, the maximum allowable axle load is 853kg for each axle and the maximum allowable noseweight is 94kg. If that is not what Bailey meant, they have documented the type approval plate wrongly.

I think I shall leave it now , we have come to the point of a circular debate.

But, you must STOP telling other caravaners to remove/ignore the manufacturers plate as you have on the other forum.

Your opinion is your opinion that's all.

 

[Buckman]

I am still struggling to find legislation where it states that there must be a statutory or mandatory weight plate on the body of a caravan as a caravan does not have a VIN number and neither does the chassis have a VIN number as it is not required for an 02 trailer. A caravan is classed as an O2 trailer However the trailer chassis by law has to have an ID number on it, but not a VIN number.
If any one could post a link to the legislation where it states that an O2 trailer requires a weight plate I would be pleased as weight plates for O2 trailers are definitely not covered by The Road Vehicles (Construction and Use) Regulations 1986.

 

[Buckman]

You mis understand on both points

I have proven there can be two MTPLM within the UK, custom and practice shows the UK operate this way, and I have given you reason as to why, that is Dot.
There is no doubt.
As for why the manufacturers choose a lower MTPLM on the manufacturers plate I suggest it's sales led.

As for Bailey Type approval plate, it does not show maximum plated loads of axle 0,1,2 but how that load is transferred to the ground, completely different to how others do it.
For example

Swift
Axle 0, 100kg
Axle 1, 1000kg
Axle 2, 1000kg.
(From an actual plate)

Bailey
Axle 0, 94kg
Axle1, 853kg
Axle2, 853kg
(From an actual plate)

Both caravans had type approval to 1800kg.

You have not proven at all that there can be two MTPLMs. You have only confirmed that two MTPLMs are in use, but not that they are used correctly and in line with the requirements as laid down in the respective EU Directive, applicable to both Construction and Use and Vehicle Approval regulations..

Of course the lower MTPLM is sales led, but then the same lower MTPLM should also appear on the statutory plate.

The type approval plate MUST always quote the maximum values allowable, hence for the Bailey case in question, the maximum allowable axle load is 853kg for each axle and the maximum allowable noseweight is 94kg. If that is not what Bailey meant, they have documented the type approval plate wrongly.

I think I shall leave it now , we have come to the point of a circular debate.

But, you must STOP telling other caravaners to remove/ignore the manufacturers plate as you have on the other forum.

Your opinion is your opinion that's all.

I am afraid that although I disagree with Lutz on some issues, in this case his statement is not incorrect about removing the plate as it carries no weight in a court of law.

 

[Simple_Life]

I am afraid that although I disagree with Lutz on some issues, in this case his statement is not incorrect about removing the plate as it carries no weight in a court of law.

Actually it does.
If you are unsure ask you regional enforcement officer.

The key words are Construction and Use. Not type or approval !!!
It is the UK Department of Transport (dft) that dictates how we use the caravan, and the EU that dictate how it's made.
The EU plate is saying it has been made to a weight obtainable, it is the Manufacturer saying how much of that weight you can use.

 

[otherclive]

I am afraid that although I disagree with Lutz on some issues, in this case his statement is not incorrect about removing the plate as it carries no weight in a court of law.

Actually it does.
If you are unsure ask you regional enforcement officer.

The key words are Construction and Use. Not type or approval !!!
It is the UK Department of Transport (dft) that dictates[/quote]

I think that you have removed something that I was going to respond to. The link to Pattersons Solicitors web pages. However I will continue. My caravan had MTPLM sticker plate near the door showing 1260kg. It had the rigid makers plate in the front locker giving 1300kg max. According to your Pattersons link if I were at 1300kg load I would still be under the 5% margin and unlikely for any action to be taken. But with a MTPLM of 1260 5% would take me to 1323Kg. So if I were to load my van to the 1300kg stated on the rigid plate in the front locker what would be my position according to your views, as I do not contravene the maximum weight as stated in the front locker by the maker? The van has been upgraded anyway to 1300kg with a new sticky plate for mounting near to the door, but which will not be mounted as they become faded and illegible anyway.

 

[Simple_Life]

I removed it for that and another reason in hind sight I thought it would confuse more than help.
Like speeding there are discretionary allowances to be had, for example damp conditions can add weight to your caravan, or if you constantly appeared before them at 4% over then measures would be taken. Highly unlikely but for example.
It would be a sad state of affairs if people appeared in court for being a few kilos over. If you had spare weight capacity in your car it's acceptable to redistribute the load at a check point

If I understand you correctly you are asking which takes precedent the locker plate or door sticker.

It would be the door sticker, as the locker plate is what the vehicle has been type approved at, but the manufacturer (door sticker) plate is instructions from them on how much of that weight you can use.

The argument cuts both ways, some are happy with the lower figure, it suits their car/licence others are not, me included, so a system is there for us.

 

[Lutz]

I think I shall leave it now , we have come to the point of a circular debate.

But, you must STOP telling other caravaners to remove/ignore the manufacturers plate as you have on the other forum.

Your opinion is your opinion that's all.

I might stop telling people to remove the NCC label (it's not a manufacturer's plate at all,but a label that the manufacturers apply solely to meet NCC requirements) if someone can where the statutory plate does not meet both Construction and Use and Vehicle Approval Requirements. If a second plate were required then all caravans would have to have one, but fact is that the NCC label is only applied by manufacturers who are members of the NCC. After all, the details that the statutory plate displays are the same whether there is a second NCC label or not, so they should suffice.
Don't get me wrong. I'm not suggesting that there mustn't be a second plate, but I am saying that there mustn't be any conflict between the two. An MTPLM is an absolute figure, so there can only be one and that would have to be the same on both plates, regardless of whether it is the higher or the lower figure.

 

[Simple_Life]

I think I shall leave it now , we have come to the point of a circular debate.

But, you must STOP telling other caravaners to remove/ignore the manufacturers plate as you have on the other forum.

Your opinion is your opinion that's all.

I might stop telling people to remove the NCC label (it's not a manufacturer's plate at all,but a label that the manufacturers apply solely to meet NCC requirements) if someone can where the statutory plate does not meet both Construction and Use and Vehicle Approval Requirements. If a second plate were required then all caravans would have to have one, but fact is that the NCC label is only applied by manufacturers who are members of the NCC. After all, the details that the statutory plate displays are the same whether there is a second NCC label or not, so they should suffice.
Don't get me wrong. I'm not suggesting that there mustn't be a second plate, but I am saying that there mustn't be any conflict between the two. An MTPLM is an absolute figure, so there can only be one and that would have to be the same on both plates, regardless of whether it is the higher or the lower figure.

Well we are getting movement.

If we look at the commercial world there is indeed a second MTPLM other than which the whole vehicle has been approved and displaying via the EU plate.

This is displayed on a DFT plate. The operator or user of the vehicle has applied to, then followed an edict from UK .gov department.

So it follows for O2 trailers that downplating is accepted, and displayed to us the user, the accepted term being MTPLM.

 

[otherclive]

I think I shall leave it now , we have come to the point of a circular debate.

But, you must STOP telling other caravaners to remove/ignore the manufacturers plate as you have on the other forum.

Your opinion is your opinion that's all.

I might stop telling people to remove the NCC label (it's not a manufacturer's plate at all,but a label that the manufacturers apply solely to meet NCC requirements) if someone can where the statutory plate does not meet both Construction and Use and Vehicle Approval Requirements. If a second plate were required then all caravans would have to have one, but fact is that the NCC label is only applied by manufacturers who are members of the NCC. After all, the details that the statutory plate displays are the same whether there is a second NCC label or not, so they should suffice.
Don't get me wrong. I'm not suggesting that there mustn't be a second plate, but I am saying that there mustn't be any conflict between the two. An MTPLM is an absolute figure, so there can only be one and that would have to be the same on both plates, regardless of whether it is the higher or the lower figure.

Well we are getting movement.

If we look at the commercial world there is indeed a second MTPLM other than which the whole vehicle has been approved and displaying via the EU plate.

This is displayed on a DFT plate. The operator or user of the vehicle has applied to, then followed an edict from UK .gov department.

So it follows for O2 trailers that downplating is accepted, and displayed to us the user, the accepted term being MTPLM.

The original post by Brasso just indicated that there was an interesting thread on another Forum that was about coming to an end. Seems it’s been given a some intensive care and transplanted here. After four pages I must say I’m not really any better informed than I was when it started. So for rightly or wrongly I will endeavour to keep my caravans maximum weight MTPLM within that set by the Swift. And since both of my plates are the same maximum even I shouldn’t be confused.

 

[Craigyoung]

..... I've ran out of popcorn !
Its like a novel !

 

[Simple_Life]

 

Further to your question regarding the caravan weights.

 

Your legal weight should be displayed on the exterior of the caravan that the traffic authorities can read.   If they wish to check your weight beyond the plates of the vehicle or the caravan then they would physically weigh you and compare this against the Gross Train Weight.   In the example you quote for the licence then they will only be looking at the plated weights displayed.   

 

Unfortunately because this could be ambiguous when being checked by the authorities can I suggest that you cover the other plate and work to the weights of the MGVW.  

This is in effect ‘down plating’ your caravan capacity.

  Please note that you must adhere to the weight requirements of the plate that is displayed.

 

I hope this answers your question.

 

Regards

 

Nigel D. Lea

 

Towing Solutions Limited

The poor dears think they have been told to cover the door plate!
I ask you.

 

[Lutz]

Well we are getting movement.

If we look at the commercial world there is indeed a second MTPLM other than which the whole vehicle has been approved and displaying via the EU plate.

This is displayed on a DFT plate. The operator or user of the vehicle has applied to, then followed an edict from UK .gov department.

So it follows for O2 trailers that downplating is accepted, and displayed to us the user, the accepted term being MTPLM.

Of course downplating is possible, but then the statutory plate must also display the downplated weight and it must be reflected in the type approval too. If the caravan manufacturer has only had one weight type approved and not a range, he would have to apply for extension of type approval to include any downplating.

Until now there still hasn't been any conclusive statement from an official source that stands up to scrutiny in reply to the question raised in the other forum.

 

[Simple_Life]

Well we are getting movement.

If we look at the commercial world there is indeed a second MTPLM other than which the whole vehicle has been approved and displaying via the EU plate.

This is displayed on a DFT plate. The operator or user of the vehicle has applied to, then followed an edict from UK .gov department.

So it follows for O2 trailers that downplating is accepted, and displayed to us the user, the accepted term being MTPLM.

Of course downplating is possible, but then the statutory plate must also display the downplated weight and it must be reflected in the type approval too. If the caravan manufacturer has only had one weight type approved and not a range, he would have to apply for extension of type approval to include any downplating.

So you now accept that a vehicle can show two different MTPLM.
Caravans are no different!
I thank you.

 

[Brasso530]

The original post by Brasso just indicated that there was an interesting thread on another Forum that was about coming to an end. Seems it’s been given a some intensive care and transplanted here. After four pages I must say I’m not really any better informed than I was when it started. So for rightly or wrongly I will endeavour to keep my caravans maximum weight MTPLM within that set by the Swift. And since both of my plates are the same maximum even I shouldn’t be confused.[/quote]
I agree OC,On the other forum it's up around 24 pages,and still no definitive answer.My elddis has both plates displaying the same figures so not affected,but it's a very interesting topic,with loads of different opinions.Only problem at moment is is its getting a bit of tit for tat and going round in circles.
The top 2/3 was supposed to be quoted.

 

[otherclive]

Well we are getting movement.

If we look at the commercial world there is indeed a second MTPLM other than which the whole vehicle has been approved and displaying via the EU plate.

This is displayed on a DFT plate. The operator or user of the vehicle has applied to, then followed an edict from UK .gov department.

So it follows for O2 trailers that downplating is accepted, and displayed to us the user, the accepted term being MTPLM.

Of course downplating is possible, but then the statutory plate must also display the downplated weight and it must be reflected in the type approval too. If the caravan manufacturer has only had one weight type approved and not a range, he would have to apply for extension of type approval to include any downplating.

Downplating is quite common for motorhome owners as they reach 70 years and don’t want the hassle of annual medical certification. They downplate to 3500 kg max or less. Subsequent owners can upgrade the weight.

 

[Lutz]

Well we are getting movement.

If we look at the commercial world there is indeed a second MTPLM other than which the whole vehicle has been approved and displaying via the EU plate.

This is displayed on a DFT plate. The operator or user of the vehicle has applied to, then followed an edict from UK .gov department.

So it follows for O2 trailers that downplating is accepted, and displayed to us the user, the accepted term being MTPLM.

Of course downplating is possible, but then the statutory plate must also display the downplated weight and it must be reflected in the type approval too. If the caravan manufacturer has only had one weight type approved and not a range, he would have to apply for extension of type approval to include any downplating.

So you now accept that a vehicle can show two different MTPLM.
Caravans are no different!
I thank you.

Of course a vehicle cannot show two different MTPLMs at the same time. Either one or the other. If there is more than one plate then the two MTPLMs must agree, as does the CoC.

A model can have an infinite number of MTPLMs within the range type approved, but for a given vehicle only one will apply and it must be plated with that one.

 

[Simple_Life]

Well we are getting movement.

If we look at the commercial world there is indeed a second MTPLM other than which the whole vehicle has been approved and displaying via the EU plate.

This is displayed on a DFT plate. The operator or user of the vehicle has applied to, then followed an edict from UK .gov department.

So it follows for O2 trailers that downplating is accepted, and displayed to us the user, the accepted term being MTPLM.

Of course downplating is possible, but then the statutory plate must also display the downplated weight and it must be reflected in the type approval too. If the caravan manufacturer has only had one weight type approved and not a range, he would have to apply for extension of type approval to include any downplating.

So you now accept that a vehicle can show two different MTPLM.
Caravans are no different!
I thank you.

Of course a vehicle cannot show two different MTPLMs at the same time. Either one or the other. If there is more than one plate then the two MTPLMs must agree, as does the CoC.

A model can have an infinite number of MTPLMs within the range type approved, but for a given vehicle only one will apply and it must be plated with that one.

So you accept downplating from EU approved MTPLM.
We agree on that.

Do you accept it is done via UK gov department for transport?

As far as I can see your objection is only to the phrase MTPLM being used on the manufacturers plate, because that phrase is reserved for EU only use?

What I'm saying is the term isn't reserved, the manufacturer has placed their own, if you like page from the handbook,a sticker on the caravan using MTPLM as a chosen phrase.because i would suggest that is what we all understand, and from a manufacturer, not EU, point of view that is exactly what it is.

I can understand your argument, but only from a phraseology point of view. What we see in practice is outside of EU control.

You have to remember that not all UK laws have been replaced with EU ones.

 

[Lutz]

So you accept downplating from EU approved MTPLM.
We agree on that.

Do you accept it is done via UK gov department for transport?

As far as I can see your objection is only to the phrase MTPLM being used on the manufacturers plate, because that phrase is reserved for EU only use?

What I'm saying is the term isn't reserved, the manufacturer has placed their own, if you like page from the handbook,a sticker on the caravan using MTPLM as a chosen phrase.because i would suggest that is what we all understand, and from a manufacturer, not EU, point of view that is exactly what it is.

I can understand your argument, but only from a phraseology point of view. What we see in practice is outside of EU control.

You have to remember that not all UK laws have been replaced with EU ones.

MTPLM is defined in an EU Directive and nowhere else. Wherever UK legislation mentions MTPLM plating requirements it always refers back to the same respective EU Directive, regardless of whether we are talking about Vehicle Approval or Construction and Use requirements. In order to avoid any misunderstandings, the term MTPLM must only be used in that context. If we don't agree on a uniform definition, we would get into the same ridiculous situation as in the case of the term 'kerbweight' where some people claim that's what is meant under 'mass in service' in the V5c (which includes 75kg for the driver), others (correctly) say it is without the driver.

In the UK, fulfilment of type approval requirements is handled by the VCA.

As I said, the label by the door is not a manufacturer's plate as required by any UK legislation but a label applied by the manufacturer to satisfy NCC requirements. That's why only NCC members have such a label. The statutory plate alone fulfils all legal requirements. Any additional plate is superfluous and only serves the purpose of repeating what is already on the statutory plate, but in a more conspicuous location.