Caravan gross weight.

[Simple_Life]

8[/quote]As I said, the label by the door is not a caravan manufacturer's plate as required by any UK legislation but a label applied by the manufacturer to satisfy NCC requirements. 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.[/quote]

I see.
In fact it is a caravan manufacturers plate, it's applied because the UK Department of Transport requested the manufacturers to do so. Possibly why you can't find any online legislation.

My educated guess is the DoT had meetings with the NCC and NTTA, caravan and car manufacturers to decided what appears on the plate and the phrases. There is some reference to this online.

As I said because it is a UK government department it becomes a UK legal requirement.

I think you have "The Cart before the Horse" it isnt at the NCC insistance, but caravan manufacturers, the NCC after all is a trade body.

They refer to the C&U regs as that's our UK legal text.

 

[Lutz]

I see.
In fact it is a manufacturers plate, it's applied because the UK Department of Transport requested the manufacturers to do so. Possibly why you can't find any online legislation.

My educated guess is the DoT had meetings with the NCC and NTTA, caravan and car manufacturers to decided what appears on the plate and the phrases. There is reference to this online.

As I said because it is a UK government department it becomes a UK legal requirement.

I think you have "The Cart before the Horse" it isnt at the NCC insistance, but manufacturers, the NCC after all is a trade body.

They refer to the C&U regs as that's our UK legal text.

The DfT can never have required fitment of a second label by the door because then it would have to be present on all caravans, whether the manufacturer is an NCC member or not. I really don't know what purpose a second plate is supposed to fulfil because the statutory plate already meets all legal requirements. Even the DfT cannot impose requirements that are not covered by legislation. The are not a legislative body. They only exercise a mandate to ensure implementation and fulfilment of legal requirements.

I agree that the NCC is a trade body, but it is a body made up not only of caravan manufacturers. We have no evidence that the requirement to apply a label by the door was at the request of the caravan manufacturers. Other members of the NCC could have dreamed up the requirement and imposed it upon them.

 

[Simple_Life]

I see.
In fact it is a manufacturers plate, it's applied because the UK Department of Transport requested the manufacturers to do so. Possibly why you can't find any online legislation.

My educated guess is the DoT had meetings with the NCC and NTTA, caravan and car manufacturers to decided what appears on the plate and the phrases. There is reference to this online.

As I said because it is a UK government department it becomes a UK legal requirement.

I think you have "The Cart before the Horse" it isnt at the NCC insistance, but manufacturers, the NCC after all is a trade body.

They refer to the C&U regs as that's our UK legal text.

The DfT can never have required fitment of a second label by the door because then it would have to be present on all caravans, whether the manufacturer is an NCC member or not. I really don't know what purpose a second plate is supposed to fulfil if the statutory plate meets all legal requirements.
I agree that the NCC is a trade body, but it is a body made up not only of caravan manufacturers. We have no evidence that the requirement to apply a label by the door was at the request of the caravan manufacturers. Other members of the NCC could have dreamed up the requirement and imposed it upon them.

Which UK made caravans don't have the caravan manufacturers plate at the door?

 

[Lutz]

Which UK made caravans don't have the caravan manufacturers plate at the door?

None have a manufacturer's plate by the door if there is statutory plate elsewhere. The statutory plate is the manufacturer's plate. If they are NCC members, they have an NCC label next to the door. Inos is an example of a UK manufacturer of series production caravans that is not a member. There are probably more small manufacturers that custom build caravans to special order and are also not members. If a plate by the door were required, it would apply just as much to imported caravans and there are many foreign manufacturers that are not NCC members and therefore don't have such a label.

 

[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.

Both Lutz and Simple Life are putting forth their views on the scenario however neither of them will put a link to the legislation that states a statutory plate must be fixed to the body of a caravan or trailer under 2300kg?
Links to solicitors and other mickey mouse organisations with no legal powers have been posted but none to legislation regarding plates on O2 trailers. In fact if a plate is on the caravan bodywork it should contain the chassis ID number and not a CRIS number.

 

[Lutz]

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.

Both Lutz and Simple Life are putting forth their views on the scenario however neither of them will put a link to the legislation that states a statutory plate must be fixed to the body of a caravan or trailer under 2300kg?
Links to solicitors and other mickey mouse organisations with no legal powers have been posted but none to legislation regarding plates on O2 trailers. In fact if a plate is on the caravan bodywork it should contain the chassis ID number and not a CRIS number.

The Road Vehicles (Approval) Regulation 2009, Schedule 4, Part 4, Paragraph 18 Plates (statutory) refers to EU Directive 76/114/EEC which lays down what must be displayed on the plate. It is valid for all trailers. There are no exceptions for O2 trailers.

 

[Buckman]

Lutz that simply states the following;
The technical provisions of: Directive 76/114/EEC as amended by Directive 78/507/EEC;

And

Where the vehicle is the subject of a multi stage build a plate is required on completion of each stage as appropriate.

No mention of any statutory plate because at present no such plate is fitted onto the caravan body. All the ones I have seen on caravans have a CRIS number on them ours included and not the same ID number that is on the chassis.
As a matter of fact most times it is not a plate on the caravan body but a sticker and there is a big difference between the two.
TBH that legislation refers to a vehicle and not a trailer. A trailer is an O2 category and not an O category. I think the legislation is referring to vehicles like for example motorhomes, vans etc where the body is afterwards to a certain spec.

 

[ProfJohnL]

Morning Prof.

Trawling via the web Dot documentation is a difficult task.

Here is another link from another source.

https://ntta.co.uk/law/law/identification-plates
The point I won't to make is that there are more regulations in force within the UK than simply European ones.

There are 3 links all stating a caravan requires a manufacturers plate, one being from Practical Caravan themselves.

Parkers I thought a good example as it's dated 2018 and contains other useful information.

Wow. Look what happens when I I'm indisposed for a day!

Let me deal with Simple life's response I've quoted.

Oscar Wilde made the famous remark, "There are lies, damned lies, and statistics.". I would like to add a codicil, " and web pages"

We should all know the www has been abused by some people who are intent on spreading malicious information, and it's been easy because the recipiants have failed to check on the accuracy before passing it on. A certain official in an oval office knows a lot about this....

But there are also many other people who try to use the internet in an honest manner, and despite their best efforts mistakes can creep in. This applies to organisations as well as individuals, and as I previously stated government portals are not immune from this.

When it comes to issues of regulations and laws, the general public will find the jargon used in the substantive documents is not easy to understand, which is why many organisations try to offer more precied readable interpretations. Sadly many such interpretations lose some of the intent of the original, and thus fail to convey the whole requirements.

For that reason alone, I do not trust third party interpretations untill I have been able to cooborate it. Simple qouting third party interpretations does nothing to prove a point of law.

Parliament makes legislation, and whilst it is generally accepted as the de facto state of play, it only becomes defined law if it is tested in the law courts.

When it comes to offences, such as excess loads and speeding, the law does not provide any latitude, if you exceed a statutory limit, even by one unit, you have commited an offence. The concept of latitude has been adopted by the organisations who would take a prosecution forward, because they know that persuing small infringements have a greater chance of failure, and therefore can have a budget impact.

It is the ACPO who have suggested a tolerance to speeding offences, not the law, and I guess the VCA have a similar approach the vehicle weight issues.

What this thread has clearly demonstrated is there is certainly public confusion about caravan weight limits, and it also suggests the caravan manufacturer's are also not entirely sure either.

It is up to each manufacturer to ensure their products comply with legislation, not the NCC. However the NCC could play a role, by only issuing a certificate for vans that fully comply with legal requirements, rather than just their own set of tests.

 

[Buckman]

Morning Prof.

Trawling via the web Dot documentation is a difficult task.

Here is another link from another source.

https://ntta.co.uk/law/law/identification-plates
The point I won't to make is that there are more regulations in force within the UK than simply European ones.

There are 3 links all stating a caravan requires a manufacturers plate, one being from Practical Caravan themselves.

Parkers I thought a good example as it's dated 2018 and contains other useful information.

Wow. Look what happens when I I'm indisposed for a day!

Let me deal with Simple life's response I've quoted.

Oscar Wilde made the famous remark, "There are lies, damned lies, and statistics.". I would like to add a codicil, " and web pages"

We should all know the www has been abused by some people who are intent on spreading malicious information, and it's been easy because the recipiants have failed to check on the accuracy before passing it on. A certain official in an oval office knows a lot about this....

But there are also many other people who try to use the internet in an honest manner, and despite their best efforts mistakes can creep in. This applies to organisations as well as individuals, and as I previously stated government portals are not immune from this.

When it comes to issues of regulations and laws, the general public will find the jargon used in the substantive documents is not easy to understand, which is why many organisations try to offer more precied readable interpretations. Sadly many such interpretations lose some of the intent of the original, and thus fail to convey the whole requirements.

For that reason alone, I do not trust third party interpretations untill I have been able to cooborate it. Simple qouting third party interpretations does nothing to prove a point of law.

Parliament makes legislation, and whilst it is generally accepted as the de facto state of play, it only becomes defined law if it is tested in the law courts.

When it comes to offences, such as excess loads and speeding, the law does not provide any latitude, if you exceed a statutory limit, even by one unit, you have commited an offence. The concept of latitude has been adopted by the organisations who would take a prosecution forward, because they know that persuing small infringements have a greater chance of failure, and therefore can have a budget impact.

It is the ACPO who have suggested a tolerance to speeding offences, not the law, and I guess the VCA have a similar approach the vehicle weight issues.

What this thread has clearly demonstrated is there is certainly public confusion about caravan weight limits, and it also suggests the caravan manufacturer's are also not entirely sure either.

It is up to each manufacturer to ensure their products comply with legislation, not the NCC. However the NCC could play a role, by only issuing a certificate for vans that fully comply with legal requirements, rather than just their own set of tests.

Excellent reply but it does not address the original question regarding the legality of the sticker or plate on the caravan. After all the CRIS number is not a legal requirement so how can an officer of the law prosecute any one using the date on the sticker as for starters the CRIS number can be off any caravan and secondly the sticker is not a mandatory statutory plate?

 

[ProfJohnL]

Hello Hickman,

UK legislation has a number of conventions, and the relevant one here is that unless specific instance's are set out in legislation, the legislation applies to present and future variations.

A vehicle is one that is propelled or used on the highway. as such small trailers are designated O2, and subject to all the provisions in the regulations unless specifically excluded.

Caravans are not considered to be a special case as far as their weight descriptors are concerned.

 

[Buckman]

Hello Hickman,

UK legislation has a number of conventions, and the relevant one here is that unless specific instance's are set out in legislation, the legislation applies to present and future variations.

A vehicle is one that is propelled or used on the highway. as such small trailers are designated O2, and subject to all the provisions in the regulations unless specifically excluded.

Caravans are not considered to be a special case as far as their weight descriptors are concerned.

Not sure who "Hickman" is, but I am wrong and type O includes trailers however the plate however it appears that all the plates that have a CRIS number are illegal as they shoudl have the same ID number throuhgout the build?

 

[Lutz]

Lutz that simply states the following;
The technical provisions of: Directive 76/114/EEC as amended by Directive 78/507/EEC;

And

Where the vehicle is the subject of a multi stage build a plate is required on completion of each stage as appropriate.

No mention of any statutory plate because at present no such plate is fitted onto the caravan body. All the ones I have seen on caravans have a CRIS number on them ours included and not the same ID number that is on the chassis.
As a matter of fact most times it is not a plate on the caravan body but a sticker and there is a big difference between the two.
TBH that legislation refers to a vehicle and not a trailer. A trailer is an O2 category and not an O category. I think the legislation is referring to vehicles like for example motorhomes, vans etc where the body is afterwards to a certain spec.

It would appear that you haven't read EU Directive 76/114/EEC, which also covers mutli-stage build plating requirements. It is easy enough to identify what is a statutory plate, because apart from the MTPLM it must also display the type approval number, maximum axle loads and maximum permissible noseweight.

There are provisions in the regulations to allow a sticker instead of a plate.

A trailer is a vehicle. Category O covers all trailers, O1 to O4, and, neglecting motor movers which are not taken into consideration for the purpose of road traffic law, all trailers are, of course, not self-propelled. Where there is reference to O2 there will be special requirements that apply only to O2 but not all other trailers.

 

[Buckman]

It would appear that you haven't read EU Directive 76/114/EEC, which also covers mutli-stage build plating requirements. It is easy enough to identify what is a statutory plate, because apart from the MTPLM it must also display the type approval number, maximum axle loads and maximum permissible noseweight

There are provisions in the regulations to allow a sticker instead of a plate.

A trailer is a vehicle. Category O covers all trailers, O1 to O4 and, neglecting motor movers which are not taken into consideration for the purpose of road traffic law, all trailers are, of course, not self-propelled. Where there is reference to O2 there will be special requirements that apply only to O2 but not all other trailers.

Yes I made that mistake however it proves at unless the ID number is on that plate it is not a mandatory or statutory plate according toe the legislation you quoted. Currently plates have a CRIS number on it and not the ID number that is on the chassis.

 

[Lutz]

It would appear that you haven't read EU Directive 76/114/EEC, which also covers mutli-stage build plating requirements. It is easy enough to identify what is a statutory plate, because apart from the MTPLM it must also display the type approval number, maximum axle loads and maximum permissible noseweight

There are provisions in the regulations to allow a sticker instead of a plate.

A trailer is a vehicle. Category O covers all trailers, O1 to O4 and, neglecting motor movers which are not taken into consideration for the purpose of road traffic law, all trailers are, of course, not self-propelled. Where there is reference to O2 there will be special requirements that apply only to O2 but not all other trailers.

Yes I made that mistake however it proves at unless the ID number is on that plate it is not a mandatory or statutory plate according toe the legislation you quoted. Currently plates have a CRIS number on it and not the ID number that is on the chassis.

The CRIS number should be identical with the VIN shown on the statutory plate, which may be different to a chassis number that the chassis manufacturer, as a Stage 1 build manufacturer, has issued. CRIS should be keeping a record of the VIN issued by the caravan manufacturer at the time the caravan was built, i.e. before CRIS registration. CRIS will presumably only issue their own number if a caravan was built in the days before caravan manufacturers had to include a VIN on the statutory plate, but that was long ago.

 

[Buckman]

It would appear that you haven't read EU Directive 76/114/EEC, which also covers mutli-stage build plating requirements. It is easy enough to identify what is a statutory plate, because apart from the MTPLM it must also display the type approval number, maximum axle loads and maximum permissible noseweight

There are provisions in the regulations to allow a sticker instead of a plate.

A trailer is a vehicle. Category O covers all trailers, O1 to O4 and, neglecting motor movers which are not taken into consideration for the purpose of road traffic law, all trailers are, of course, not self-propelled. Where there is reference to O2 there will be special requirements that apply only to O2 but not all other trailers.

Yes I made that mistake however it proves at unless the ID number is on that plate it is not a mandatory or statutory plate according toe the legislation you quoted. Currently plates have a CRIS number on it and not the ID number that is on the chassis.

The CRIS number should be identical with the VIN shown on the statutory plate, which may be different to a chassis number that the chassis manufacturer, as a Stage 1 build manufacturer, has issued. CRIS should be keeping a record of the VIN issued by the caravan manufacturer at the time the caravan was built, i.e. before CRIS registration.

No O2 trailer has a VIN number. Thye have an ID number which is different to a VIN or CRIS number.

 

[Lutz]

No O2 trailer has a VIN number. Thye have an ID number which is different to a VIN or CRIS number.

The VIN is, by definition, the ID number. Every trailer subject to type approval (introduced at the latest in 2014) must have a VIN (or ID).

Without a VIN how else would a caravan manufacturer be able to trace a caravan in the event of a product recall?

 

[Dustydog]

I’m BOB’d. Bored of Brexit but this thread is mind boggling. All my caravans over 40 years have been fully legally compliant at the time, plates and so on. If we can’t crack this what chance have the boys in blue got

 

[Buckman]

No O2 trailer has a VIN number. Thye have an ID number which is different to a VIN or CRIS number.

The VIN is, by definition, the ID number. Every trailer subject to type approval (introduced at the latest in 2014) must have a VIN (or ID).

Without a VIN how else would a caravan manufacturer be able to trace a caravan in the event of a product recall?

A VIN should have 17 number and letters and does not fit in with the ID number on the chassis however if you mean the ID?VIN number are one and the same breaking down the VIN/ID number on a trailer does not make sense according to this link which shows how a VIN number is decoded.
Can any one show that the CRIS number on caravan plate or sticker matches up with the ID number on the chassis of the trailer taking into consideration that the sticker is neither mandatory or statutory and displays the CRIS number and not a VIN or ID number?
For Lutz's information the caravan manufacturer uses the customer's details and maybe the CRIS number for a recall and not the ID number on the trailer. I have no idea on how a recall is done on any other trailer.
Maybe Lutz can advise further?

 

[Lutz]

As CRIS registration is voluntary, the caravan manufacturer must have a way of tracing a caravan that is not CRIS registered. Besides, at the time the caravan leaves the factory, the caravan must already have its statutory plate fitted and that takes place before CRIS registration. Without a VIN there would be no way of tracing a caravan until that happens.
It is left up to the caravan manufacturer how he codes the VIN. He is issued a block of 17 digit numbers which he can use at his own discretion. As the link that you supplied explains, the VIN code within the car industry follows a standard format, but trailer manufacturers are not under any obligation to follow suit.
Only the caravan manufacturer would have any record of how a particular chassis number, if any, is linked to the respective VIN.

 

[Buckman]

As CRIS registration is voluntary, the caravan manufacturer must have a way of tracing a caravan that is not CRIS registered. Besides, at the time the caravan leaves the factory, the caravan must already have its statutory plate fitted and that takes place before CRIS registration. Without a VIN there would be no way of tracing a caravan until that happens.
It is left up to the caravan manufacturer how he codes the VIN. He is issued a block of 17 digit numbers which he can use at his own discretion. As the link that you supplied explains, the VIN code within the car industry follows a standard format, but trailer manufacturers are not under any obligation to follow suit.
Only the caravan manufacturer would have any record of how a particular chassis number, if any, is linked to the respective VIN.

Lutz, caravans in the UK are not subject to recalls like vehicles and there is no national database for caravans. Manufacturers will be aware of the contact details for the first owner and after that it is not their problem.
I would think that all UK manufactured caravans are on an ALKO chassis as far as I am aware and that the chassis will have the ID number stamped on it before delivery to the manufacturer.
When the caravan body is added at every stage there should be a plate with the chassis ID number on it fitted, but we all know that this does not happen in the caravan industry which is why the sticker on the body has a CRIS number.
BTW interesting conversation!

 

[otherclive]

I had a 2009 French caravan that was officially imported. Unlike my previous UK vans going back from memory to 1998 it had no tally plate near the door or anywhere else either. Neither did it have CRIS registration. What it did have was a long alphanumeric stamped on the A -frame together with three sets of stamped weights near to the coupling head. These were 100kg 1000kg and 1000kg. I took these to be noseweight, MTPLM, and axle weight. In the axle 1000kg was stamped. I registered it with CRIS who used the alphanumeric string. Call it a VIN but it was not capable of being decoded to give the standard VIN information. EG only Trigano could give me the build date. Although examination of plastic components got me pretty close.

 

[otherclive]

Buck man
I think a lot of Eldiss are on BPW chassis but with Alko taking over BPW that will or may have now changed.

 

[Buckman]

Buck man
I think a lot of Eldiss are on BPW chassis but with Alko taking over BPW that will or may have now changed.

Our 2016 Elddis was on a BPW chassis but the 2018 is on an ALKO chassis.

 

[Lutz]

Lutz, caravans in the UK are not subject to recalls like vehicles and there is no national database for caravans. Manufacturers will be aware of the contact details for the first owner and after that it is not their problem.
I would think that all UK manufactured caravans are on an ALKO chassis as far as I am aware and that the chassis will have the ID number stamped on it before delivery to the manufacturer.
When the caravan body is added at every stage there should be a plate with the chassis ID number on it fitted, but we all know that this does not happen in the caravan industry which is why the sticker on the body has a CRIS number.
BTW interesting conversation!

Caravans can be subject to a recall, the same as any item sold, whether it is a vehicle or not, especially if user safety is at stake. The manufacturer will always have a record of which caravan with which VIN went to which dealer. The dealer would then have the task of locating the customer, again using the VIN, maybe in conjunction with CRIS registration, as a method to ensure traceability.
Not all caravans are built on complete chassis. I am told that some caravan manufacturers build their own chassis from components supplied by AlKo and the suchlike, in which case there will not be a Stage 1 build and consequently no chassis number, just like cars which don't have a chassis number because they don't have a chassis (well, most of them today don't).
If a caravan manufacturer changes the source of the chassis that he uses he will only be able establish the actual breakpoint by the VIN. That just shows the importance of the VIN.

 

[Buckman]

Lutz, caravans in the UK are not subject to recalls like vehicles and there is no national database for caravans. Manufacturers will be aware of the contact details for the first owner and after that it is not their problem.
I would think that all UK manufactured caravans are on an ALKO chassis as far as I am aware and that the chassis will have the ID number stamped on it before delivery to the manufacturer.
When the caravan body is added at every stage there should be a plate with the chassis ID number on it fitted, but we all know that this does not happen in the caravan industry which is why the sticker on the body has a CRIS number.
BTW interesting conversation!

Caravans can be subject to a recall, the same as any item sold, whether it is a vehicle or not, especially if user safety is at stake. The manufacturer will always have a record of which caravan with which VIN went to which dealer. The dealer would then have the task of locating the customer, again using the VIN as a method to ensure traceability.
Not all caravans are built on complete chassis. I am told that some caravan manufacturers build their own chassis from components supplied by AlKo and the suchlike, in which case there will not be a Stage 1 build and consequently no chassis number.
If a caravan manufacturer changes the source of the chassis that he uses he will only be able establish the actual breakpoint by the VIN. That just shows the importance of the VIN.

I cannot recall of hearing about any caravan manufactured in the UK being subject to a recall for safety reasons. Recalls generally happen if there is an issue with the design or build i.e. heating issue or water leaking through a sky light but certainly not for safety. How would any manufacture trace a caravan that ahs been sold on?