Losing weight!

[DaveA1]

I have three plates on mine

On the axle,
Including, Order no ,
customer; Swift,
date 15-jul-2011
Type B1200
Capacity 1350

In the front Locker;
Nose weight, 100 kg
Capacity, 1350 kg

NCC next to the door:
Visible to everyone.

 

[Lutz]

But that can be compared, by looking at both and checking?

I can't see why the NCC plate, should they want it, give values well within the type approval plated values.

A lower MTPLM on the NCC label is purely a marketing ploy, suggesting that the caravan can be towed with a lighter car or a car with a lower towload limit, thereby making it more attractive to a wider market. It also (falsely) makes the caravan more attractive to owners with a category B driving licence, limited to a 3500kg combination weight.

Maybe in Germany it is inside the front locker, but it is not there on our 2018 UK built caravan. See https://assets.publishing.service.g...hicle-approval-inspection-manual-trailers.pdf

https://assets.publishing.service.g...hicle-approval-inspection-manual-trailers.pdf

No the requirement to display a statutory plate applies in the UK, too. If it's not in the front locker, but most are, it must be somewhere else. It can be on the chassis, but seldom is, because it could be confused with the chassis manufacturer's plate, which is also located there.
The links that you have provided apply to individual vehicle approval only and not to whole vehicle type approved caravans.

 

[JTQ]

A lower MTPLM on the NCC label is purely a marketing ploy, suggesting that the caravan can be towed with a lighter car or a car with a lower towload limit, thereby making it more attractive to a wider market. It also (falsely) makes the caravan more attractive to owners with a category B driving licence, limited to a 3500kg combination weight.

Seems as you say "false" in that if the "B" license holder works on a lowered NCC MTPLM figure, to keep just under 3500 kgs, would not the legal position actually be based on the true "type approval MTPLM" figure? Based on my perception the license issue is based on plated values, not actual in use at the time.

With the growing percentage just holding a "B" license, this might become more than an academic point.

 

[Lutz]

Seems as you say "false" in that if the "B" license holder works on a lowered NCC MTPLM figure, to keep just under 3500 kgs, would not the legal position actually be based on the true "type approval MTPLM" figure? Based on my perception the license issue is based on plated values, not actual in use at the time.

With the growing percentage just holding a "B" license, this might become more than an academic point.

Yes, that is my understanding, too (that a higher MTPLM on the statutory plate takes precedence over what's on the NCC label), but that would make nonsense of the NCC label. Nevertheless, when conducting roadside checks the powers-that-be seem to be willing to accept what's on the NCC label, probably because no-one has ever questioned which of the two MTPLM's (if there's a different on on the statutory plate) is the definitive one.

 

[Darren.H]

Lots of mis information going on here.

Yes, that is my understanding, too (that a higher MTPLM on the statutory plate takes precedence over what's on the NCC label), but that would make nonsense of the NCC label. Nevertheless, when conducting roadside checks the powers-that-be seem to be willing to accept what's on the NCC label, probably because no-one has ever questioned which of the two MTPLM's (if there's a different on on the statutory plate) is the definitive one.

You have argued this for years and refuse to accept what has been posted on various forums including a written reply from an authoritive body.

I stated very simply that a manufacturer can stipulate a weight that they wish for their equipment supplied as done in the commercial world its called downplating so of course there has to be a higher weight to downplate from!
None the less the Manufacturers plate takes precedence as proved.

As far as the weight issue, as I posted MIRO includes 90% full onboard water tank and a full flush tank, so if the onboard water tank is empty the caravan is more than likely under MTPLM.
Also in the commercial world you are allowed to be 3% over so I would imagine it to be true with trailers

 

[Lutz]

I have three plates on mine

On the axle,
Including, Order no ,
customer; Swift,
date 15-jul-2011
Type B1200
Capacity 1350

In the front Locker;
Nose weight, 100 kg
Capacity, 1350 kg

NCC next to the door:
Visible to everyone.

If you had a caravan built after whole vehicle type approval was implemented in 2014, it would have a further plate on the chassis and the one in the front locker would have more information on it than just noseweight and capacity.

 

[Lutz]

Lots of mis information going on here.


You have argued this for years and refuse to accept what has been posted on various forums including a written reply from an authoritive body.

I stated very simply that a manufacturer can stipulate a weight that they wish for their equipment supplied as done in the commercial world its called downplating so of course there has to be a higher weight to downplate from!
None the less the Manufacturers plate takes precedence as proved.

As far as the weight issue, as I posted MIRO includes 90% full onboard water tank and a full flush tank, so if the onboard water tank is empty the caravan is more than likely under MTPLM.
Also in the commercial world you are allowed to be 3% over so I would imagine it to be true with trailers

Of course a manufacturer can downplate, but then the downplated value must show up on the statutory plate, too. The "authoritative body" that you refer to has only confirmed accepted practice. They were very careful to point out that it is not necessarily the legal position, but to leave it to the courts to pass judgment. To my knowledge, this has never been done.

As far as MIRO is concerned, one should be aware that the MIRO figure applies only to the caravan that the caravan manufacturer submitted for type approval. not to the particular caravan in question. There could be a difference in spec. So long as the manufacturer's application for type approval process covers the full range, that is quite acceptable.

 

[Darren.H]

Not even going there

 

[Buckman]

Not sure about the argument about plates etc as OP was complaint about low payload and maybe exceed MTPLM by several kgs.
However I supposed that if the statutory plate on the axle has a higer value than the NCC sticker then maybe all is okay? However either way we will endeavour to move some stuff from the caravan into the roof box on the car to comply with legislation.
TBH I think a fine of £250 is a bonus if I wake up without back ache! LOL!

 

[Darren.H]

Not sure about the argument about plates etc as OP was complaint about low payload and maybe exceed MTPLM by several kgs.
However I supposed that if the statutory plate on the axle has a higer value than the NCC sticker then maybe all is okay? However either way we will endeavour to move some stuff from the caravan into the roof box on the car to comply with legislation.
TBH I think a fine of £250 is a bonus if I wake up without back ache! LOL!

The whole plate arguement is tbh nonsense.
The authorities will always go to the manufacturers stated operational weight.

To dumb it down,
The Caravan model is type approved as in the many thousand that are made
Then your individual caravan is downplated by the manufacturer to what ever they want it to be, you as a user of that individual caravan must comply. Its that simple.

I would strongly suggest you go weigh it with empty water tanks, you maybe surprised.
I have within 8 miles of my house a free to use axle type vehicle weigh Station operated by local gov body. Have a Google you too may find one.
The department used to be called Trading Standards, its now called Joint Body.

 

[Lutz]

The whole plate arguement is tbh nonsense.
The authorities will always go to the manufacturers stated operational weight.

To dumb it down,
The Caravan model is type approved as in the many thousand that are made
Then your individual caravan is downplated by the manufacturer to what ever they want it to be, you as a user of that individual caravan must comply. Its that simple.

You say, "The authorities will always go to the manufacturers stated operational weight." but that is the weight that is shown on the statutory plate. The NCC label by the door doesn’t comply with the requirements of a statutory plate and there are no provisions in legislation for two plates anyway. It wouldn’t make sense either as no-one would know which of the two MTPLM’s applies.
If a caravan or motorhome is downplated then the statutory plate must be replaced by another plate displaying the lower figure.

 

[Darren.H]

You say, "The authorities will always go to the manufacturers stated operational weight." but that is the weight that is shown on the statutory plate. The NCC label by the door doesn’t comply with the requirements of a statutory plate and there are no provisions in legislation for two plates anyway. It wouldn’t make sense either as no-one would know which of the two MTPLM’s applies.
If a caravan or motorhome is downplated then the statutory plate must be replaced by another plate displaying the lower figure.

This is a one time response, you to my knowledge having been posting about this for 7 years, even though you have been told across several forums you are wrong!

The statutory plate as you call it would be the plate used to show type approval compliance and attached to the bulkhead as per.
The NCC plate as you again call it, is the manufacturers plate.

A manufacturer can place restrictions on the product as they so wish, those restrictions are binding. Common sense to most

The End

 

[Buckman]

A manufacturer can place restrictions on the product as they so wish, those restrictions are binding. Common sense to most

The End

That may be an incorrect statement as legislation over rides any manufacturer guidelines depending on manufacturer i.e. in the case of a caravan there is more than one manufacturer i.e. chassis and body. The manufacturer of the chassis could have a higher load rating than the manufacturer of the caravan.
A reply from the old VOSA many years ago indicated that the weight sticker on the side of a caravan body was not mandatory or statutory and had no bearing in law and could not be enforced in a court of law however best is not to exceed the manufacturer's guidelines.
Also a manufacturer can place restrictions on a product but legislation like CRA 2015 would over ride their restrictions however that is a whole new topic.
Either way we are sticking within the law so I guess the topic can be closed to prevent further arguments.

 

[Lutz]

This is a one time response, you to my knowledge having been posting about this for 7 years, even though you have been told across several forums you are wrong!

The statutory plate as you call it would be the plate used to show type approval compliance and attached to the bulkhead as per.
The NCC plate as you again call it, is the manufacturers plate.

A manufacturer can place restrictions on the product as they so wish, those restrictions are binding. Common sense to most

The End

I am not aware of any statement by official sources that said I was wrong.
A statutory plate is a legally required plate. No other plate is. It is by definition in the regulations the manufacturer’s plate. The NCC label is no more than a consumer information label. It doesn’t even comply with the requirements of a statutory plate and it is not covered by any piece of UK legislation.

 

[JTQ]

Common sense to most

Not "common sense" to all though, me included, I see it just as a confused mess without logical "sense".

The manufacturer complies with legislation and gets type approval for that trailer, with the load carrying capabilities and limitations it has.

Then he places further restrictions on its weight limits, adds a supplementary label and it is now claimed these take precedence, over the legal type approval values.

But furnish him with money, and with nothing more than possibly altering their records and posting, you a new sticker upping these previously mandatory limits, you have some new mandatory limit.

I beg to ask where the "common sense", comes in? Certainly in physical terms, affecting any safety issues, one presumes the Government's reason for the road side inspecting. Not to see if you paid for a new sticker.

 

[Darren.H]

That may be an incorrect statement as legislation over rides any manufacturer guidelines depending on manufacturer i.e. in the case of a caravan there is more than one manufacturer i.e. chassis and body. The manufacturer of the chassis could have a higher load rating than the manufacturer of the caravan.
A reply from the old VOSA many years ago indicated that the weight sticker on the side of a caravan body was not mandatory or statutory and had no bearing in law and could not be enforced in a court of law however best is not to exceed the manufacturer's guidelines.
Also a manufacturer can place restrictions on a product but legislation like CRA 2015 would over ride their restrictions however that is a whole new topic.
Either way we are sticking within the law so I guess the topic can be closed to prevent further arguments.

You need to read other regulations, as I say downplating is common practice in the commercial world and also quite common in the Horse community too.
It makes not a jot of difference how many components are used each being plated to indicate intended restrictions, the manufacturer is ultimately responsible.

Example,
3000 box trailers put together by a manufacture, gain type approval of 4000kg MTPLM

1000 are INDIVIDUALLY downplated to 1000kg and sold with this restriction
1000 are INDIVIDUALLY downplated to 2000kg and sold
1000 are untouched.

That in essence is why two plates appear on caravans, otherwise the 3 lots would need type approval for each weight category, a nonsense when the weight is being decreased from an approved figure.

 

[Darren.H]

As I say go read more, Horsey people downplate all the time, a box intended for 2 horses is not uncommon to contain 1 horse with a downplated MTPLM,
Over and very definitely out!

 

[Parksy]

This is a one time response, you to my knowledge having been posting about this for 7 years, even though you have been told across several forums you are wrong!

The statutory plate as you call it would be the plate used to show type approval compliance and attached to the bulkhead as per.
The NCC plate as you again call it, is the manufacturers plate.

A manufacturer can place restrictions on the product as they so wish, those restrictions are binding. Common sense to most

The End

As I say go read more, Horsey people downplate all the time, a box intended for 2 horses is not uncommon to contain 1 horse with a downplated MTPLM,
Over and very definitely out!

Calm Down!
Agree to disagree, don't take it personally when you and another member disagree.

 

[Darren.H]

Calm Down!
Agree to disagree, don't take it personally when you and another member disagree.

I am calm I'm not annoyed taking things out of context.
There's only so many ways the same thing can be said!
As I say no more comments on this topic.

 

[Damian]

As I say no more comments on this topic.

That is probably the best course.

 

[Lutz]

I think there is simply a misunderstanding between DarrenH and myself. I get the impression that Darren thinks that manufacturers can’t downplate. Of course they can, but downplating needs a new statutory plate and the CofC must be reissued to reflect the lower MTPLM. In fact, in the case of a downplated motorhome this must be done in order for the V5c to be amended. Caravans are no different except that they aren’t issued with a V5c.

OK, I’ll leave it at that.

 

[Buckman]

I am really sorry I mentioned losing weight, but perhaps still being over the MTPLM and sincerely apoligise for my thread which has become very controversial and nothing to do with small payloads.

 

[Parksy]

I am really sorry I mentioned losing weight, but perhaps still being over the MTPLM and sincerely apoligise for my thread which has become very controversial and nothing to do with small payloads.

No apology needed Buckman, forum members do disagree from time to time, especially about technical issues, and it's no big deal.
We only step in to try to prevent forum members becoming upset with each other and no longer using the forum.

 

[Lutz]

Just a small correction to my last post. I should have said, "I get the impression that Darren thinks that I believe manufacturers can’t downplate." I realised my mistake after it was too late to edit.
Maybe my statement is a bit clearer now.

 

[Parksy]

The O.P. wasn't about downplating anyway, he was worried about a weight increase due to the use of a memory foam mattress.