M.I.R.O

[TheTravellingRooster]

Hi to you all.Further to my postings #21 & #23.I have delved further into the EU Directive 95/48/EC and scanned the text for the original definition (it was not MiRO or Mass of Vehicle) it was very specific and related to the old term of kerbweight as in the 1986 Construction and Use Regulations and also to the now (since 20th September 1995)definition as ammended by the EU. In 2006 I used this quoted statement from the directive to endorse my case with Towsafe and erroneous data on their site relevant to my car.
I am unable to find that particular piece of data on the relavent website!!??,since then thousands of web searches have been placed in chronological order on the Google Search Engine and I believe it has got buried!!.
However I have located an extremely good publication by The Caravan Club (Thinking of buying a tow car?) on page 14 of 28 there is a direct reference to the EU Directive. Paragraph 2 :- As defined by EU Directive 95/48/EC(issued in September 1995).
This publication is available as a PDF Download and well worth the 18 sheets of A4 as a reference (I have kept an older version in the caravan at all times)I will put this one in the caravan next trip out.

 

[Lutz]

The full title of 95/48/EC is "COMMISSION DIRECTIVE 95/48/EC of 20 September 1995 adapting to technical progress Council Directive 92/21/EEC relating to the masses and dimensions of motor vehicles of category M1" Note the words "Motor Vehicle" and Category M1. It therefore does not apply to trailers (caravans) which are Category O vehicles. Any extension to cover the latter would have to be documented in a draft proposed directive, details of which, should they exist, have eluded us so far.

 

[TheTravellingRooster]

The full title of 95/48/EC is "COMMISSION DIRECTIVE 95/48/EC of 20 September 1995 adapting to technical progress Council Directive 92/21/EEC relating to the masses and dimensions of motor vehicles of category M1" Note the words "Motor Vehicle" and Category M1. It therefore does not apply to trailers (caravans) which are Category O vehicles. Any extension to cover the latter would have to be documented in a draft proposed directive, details of which, should they exist, have eluded us so far.

With respect I have never said nor inferred that it (the original,I have made mention of again in my post previous to this)did relate to caravans or trailers of any kind.My reference to (EU Directive 95/48/EC)was in strict reference to the Kerbweight of Motor Vehcles.I believe that I said or suggested that it/a an other; would be implimented in the near future in the UK.It actually will be an ammendment to an existing Construction and Use piece of legislation already in use in Europe Proper.Download the Caravan Club item that I have refered to and in the Go Caravan magazine it referes to the current implimetation of the NEW to be MEANING OF MiRO.

 

[ProfJohnL]

With respect Rooster,
The only authority to take at face value is the EU directive, or relevant UK legislation. It has been known for respected organisations to get their facts wrong, and miss-quote or interpret the meaning of official legislation incorrectly.

Even this erstwhile publication PC get some of its information wrong, or puts the wrong emphasis on some information, so the moral is, be aware of what is published and beware of what is published.

 

[Lutz]

I would just like to add and repeat that the term 'kerbweight' is mentioned nowhere in the Directive. The term MIRO is used throughout.

 

[Ancientcaravanner]

Sorry Prof - I am not saying that - I am trying to say that the noseweight would then be something realistic. It would force the manufacturers to look at where they install batteries etc. as the current noseweights with gas bottles and battery installed would be in the hundreds of Kg. The noseweight should be in the brochures.

 

[Lutz]

Whether or not gas bottles and/or batteries are included in the MIRO is not going to force manufacturers to publish noseweights.
To perhaps put the whole issue of MIRO into perspective, over here on the Continent where manfacturers already have to certify MIRO for vehicle registration purposes, the registration certificate for my caravan (the equivalent to the V5c in the UK) shows a range 1250 to 1410kg. The manufacturer obviously doesn't weigh each caravan as it leaves the factory, but quotes a range to take care of different levels of equipment fitted. Such a range of 160kg allows for a lot of leeway regarding type of gas bottle, size of battery, etc. As there is no need for an absolute value for MIRO (no other law references it) quoting a range is quite in order.

 

[ProfJohnL]

Hello again Ancient caravanner,
With the greatest of respect, I cannot understand your persistence in wanting manufactures to publish a fixed nose load value. They know that in less than 0.01% of cases it will be matched in a road going caravan. There are so many variable factors involved, it can’t even be suggested as a reliable indicative value.

It is, and has been, a fact of caravanning life that the driver needs to ensure the caravan is loaded correctly to achieve an acceptable nose load. The only way a driver can conclusive know their outfit is both legal and safe (note these two issues are not necessarily related) is by measuring the nose load.

The only nose weight guidance the manufactures can offer is the range defined by the EU's legal minimum determined by the mass of the trailer, and the maximum defined by the mechanical construction of the chassis.

Give the same caravan and luggage to two different caravanners, and they will load the caravan and produce two different nose loads. It is equally possible to take a typically loaded caravan and re load it so the nose loads are way out of the designed and legal ranges. - its all down to how the individual driver loads the caravan, and that is something the manufactures cannot possibly legislate for.

Even if the manufacture used 'standard' gas bottles and battery to produce a 'MIRO' nose load, as soon as the owner changes one or the other of the items the nose load will change, and of course add any luggage and other bits and pieces and the original figure has no relevance what so ever. Don't forget that includes the cutlery in the draw, the bread in the locker, the crockery, the torch etc etc they may all be small items but they all affect the nose load.

Similarly the same caravan's nose load measured at 350mm hitch height will be different to the measurement at 420mm.
Any changes of MIRO to include caravans and certain equipment will simply not force manufactures to publish a nose load figure, or to reconsider their designs to normalise nose loads

 

[TheTravellingRooster]

Hi to you all ,and anyone that has not yet had a problem with noseweigh.This is an issue that few understand and some will never. We cannot all afford to use 150kg MAX HITCHWEIGHT CHELSEA TRACTORS.
My 1997 Volvo V70 T5 CD Auto has a Max Tow Weight of 1600kgs & a maximum downward force on the towball of 75kgs.Most times that has not been a problem,however in September of 2007 I collected (with an empty car and one passenger in the front) a 1992 Fleetwood Colchester 1850 Twin Axle from Nottingham (No Battery,No Gas Bottle but a Spare Wheel)the van was completely dry of fluids.It was infact in its' MiRO state as was (Ex Factory Weight) when built.
For the benefit of the new to caravanning, Fleetwood listed the van as Ex Works Weight 1140kgs (+/- 5%),Payload Margin 460kgs making The Maximum Authorised Weight 1600kgs. Nose weight was not on the agenda. I had checked out the van figures before agreeing to purchase.
The front of the van was so heavy when I came Hitch Up that I had my doubts about towing it home, I took out the spare wheel (25kgs) and moved it and all of the front cushions to the rear dinette.I then proceeded to drive home,I used the old 'A' route to deliberately keep below motorway pace.
The caravan later with a noseweight gauge registered off the scale (estimated at 120/125kgs) in the state that I collected it.After doing my balancing act the noseweight was brought into a more managable figure of 95kgs.
Short of stealing part of someones garden wall I had little choice but the action that I had taken with what I had to play with.
If nose weighs were a published figure then you would know what you were about to deal with; before you found your front wheels off the floor!!!!,and your front wheel drive with NON (Drive, that is).
Oh, by the way; the caravan when weighed on a rather accurate weighbridge recorded a massive 40kgs OVER the +5% allowance for manufacturing tollerances. I much later found out that Fleetwood were not regarded as giving accurate figures for their products.
IF NOSE WEIGHT IS NOT IMPORTANT as a declared figure like the others:- MiRO & MTPLM ;then what do you collect your new van with? A MASSEY FERGUSON TRACTOR!!!! just in case it should well exceed the maximum weight on the tow ball.

 

[Damian]

+Regardless of the weight a towball can take, you are limited to a max of 100kg on the hitch head in any case, due to the Al-Ko or BPW chassis limit.
So, even if your towball can take 150kg, you still have to load to a MAX of 100kg.

 

[Lutz]

Both noseweight and MIRO are variable, depending on levels of equipment and, in the case of noseweight, the distribution of these variable weights. Only MTPLM is an absolute figure. Even if an EU Directive to extend the definition of MIRO to cover caravans comes into effect, it won't change the fact that both it and noseweight will remain specific to each caravan and no manufacturer will be able to certify these figures without reference to a particular chassis number. Any data published in brochures etc. can only be for rough guidance, just like MIRO (or kerbweight) for cars.
There is only one way to be absolutely sure of not exceeding noseweight limits when one picks up one's new caravan from the dealer and that is to take along a couple of sacks of sand or potatoes with you before you go as a precautionary measure for use as potential ballast, just in case the noseweight turns out to be excessive. No EU Directive will change that.

 

[TheTravellingRooster]

Hi to Domain-Moderator and Lutz,Yes I agree on both counts.I had overlooked the inclusion of the imposed weights on the hitch head by both caravan chassis manufactures.
However if (YET ANOTHER DICTAT)or perhaps a draft proposal was put in motion by The NCC to the effect that Caravan Manufacturers publish the NOSE WEIGHT ( Nose Weight Gauge in place & Jockey Wheel clear of the floor)of each individual NEW off THE LINE van, whether it be Single or Twin Axle in its' ready to the customer state.
The alternative could be that the Caravan Dealer deals (pardon the pun)with that,it is not uncommon for dealers to put the finishing touches into vans prior to collection by the customer. The dealer could even progress this notion to the used van market that has not yet come into the new safety net.
In either senario the unsuspecting & often overjoyed recipient of the van does not get what I got upon one of my collection exercises.

 

[Lutz]

Surely the easiest solution, if it is a matter of concern, is to phone the dealer prior to picking the caravan up and ask him to measure the noseweight in advance of the hand-over so that you can come prepared with any ballast that you may need.

 

[ProfJohnL]

Hi rooster,

Your experience just goes to highlight the need for the driver to check the nose load before towing. That is especially true of an unknown trailer, as you found out.

Some manufacturers do publish a nose load figure, and some are surprisingly high but it is only the ex-works figure. For the many reasons given above, manufactures will find it nigh on impossible to publish any other nose load figure except for the range of allowable nose load for the trailer.

I assume your experience occurred when collecting a caravan from a dealer, I certainly go along with Lutz suggestion of calling ahead to confirm the actual nose load, but even that has problems, because the nose load is affected by the height of the tow hitch when the load is applied, and is especially tricky for TA caravans.

Taking some items for ballast is also a sensible approach, even my trick of using a a water container which can be filled or emptied to get a suitable trim.
As a private driver of the outfit you are responsible for trimming for the correct nose load – no one else.

 

[TheTravellingRooster]

Hi again to Lutz & Prof John L,yes I am well aware that as the responsible driver of the outfit it is mine & mine only :-Duty/Requirement in Law to conform with all requirements.Also to assertain wherever possible the details that will make that/those requirements easier to comply with.
Yes the Fleetwood Colchester 1850 Twin Axle was collected from a private seller and my Tow Ball ( when not connected) is at the maximum guide height (centre of ball) Page 8,The Caravan Towing Guide issued by The NCC in co-operation with The C&CC & The CC and when it has a 75kg load imposed upon it (its' maximum permitted & the cars) it falls to 15mm above the minimum height at its' centre,all checked on level ground.The problem was that despite asking before I collected and being told it was at the 75kgs/80kgs mark it wasn't ,it had been weighed using bathroom scales that should have been recycled into tin cans; years before.
That said, the new 2001(to us)one owner from new van before it was collected 30th July 2010(from a Dealer,not as large as was but still national)was verified as 80kgs and was pulled away in the trim state as it left the factory (Elddis) in 2001.
The potential problem of non declared nose weight with an empty van is still in the Unfortunate Domain of The Uninitiated/Potential New Caravanner.
If the hobby/interest/pastime is to recruite new initiates then,:- THERE HAS TO BE A LOT MORE INFO AVAILABLE and EASILY FOUND & above all FACTUAL.

 

[Lutz]

I really don't see how any manufacturer's certification of noseweight, if such a requirement were ever to be come into being, is going to resolve the problems illustrated in the two examples above. In both cases the caravan that was being picked up was not straight from the factory so how can any manufacturer's certificate, which can only be valid for the ex-works condition at the time the caravan left the production line be assumed to still apply at a later date?
The problem would only be resolved if any change in noseweight due to a later modification to the caravan would have to be documented, too. Our caravan came ex-works without a spare wheel. Before delivery, the dealer fitted one in the front locker at my request. That, of course, had a significant effect on the noseweight and would have made any manufacturer's certificate meaningless.
While touring on holiday a few week's ago, due to shuffling loads around inside the caravan, including using up stocks of food and drink, and storing dirty washing elsewhere than in the wardrobe where the clean clothes are kept, for example, the noseweight of our caravan varied from about 50 to 90kg before adjustment. This is something one just has to be aware of and be able to act accordingly. No certification of any sorts is going to help there.

 

[TheTravellingRooster]

I really don't see how any manufacturer's certification of noseweight, if such a requirement were ever to be come into being, is going to resolve the problems illustrated in the two examples above. In both cases the caravan that was being picked up was not straight from the factory so how can any manufacturer's certificate, which can only be valid for the ex-works condition at the time the caravan left the production line be assumed to still apply at a later date?
The problem would only be resolved if any change in noseweight due to a later modification to the caravan would have to be documented, too. Our caravan came ex-works without a spare wheel. Before delivery, the dealer fitted one in the front locker at my request. That, of course, had a significant effect on the noseweight and would have made any manufacturer's certificate meaningless.
While touring on holiday a few week's ago, due to shuffling loads around inside the caravan, including using up stocks of food and drink, and storing dirty washing elsewhere than in the wardrobe where the clean clothes are kept, for example, the noseweight of our caravan varied from about 50 to 90kg before adjustment. This is something one just has to be aware of and be able to act accordingly. No certification of any sorts is going to help there.

I am not suggesting nor have I in any of my inputs on this now rather sticky subject;that there should be certificates of any nature to accomodate any MOVING GOAL POSTS.
A caravan when leaving the factory of the manufacturer has built into its' inception build/history facts & figures often shown in the Original Launch Blurb and or in the more detailed Sales Brochure.It is this detail ie:-MiRO,MTPLM,Shipping Length,Body Length etc etc that helps prospective purchasers make VALUED JUDGEMENTS & DECISIONS.
GIVE US A CLUE!!,NOSEWEIGHT AT NEW SOURCE (on the rollout from the production line)could be disclosed,in the same light as all other values are.
Any additions/repositioning for what ever reason to the standard spec' (at NEW or as PRE-OWNED) is going to affect the weight on the BALL/HITCH that goes without saying.This also ADDS WEIGHT (pardon the pun) to the STUPPIDY of checking NOSEWEIGHT by putting scales etc UNDER THE JOCKEY WHEEL.The Jockey wheel can often be as far back as 16" -18" from the Hitch Cup.

 

[Lutz]

Whereas publishing MTPLM, shipping length, body length etc. doesn't pose a problem, variables such as MIRO and noseweight can only be quoted for guidance purposes only in any literature. As I mentioned before, the registration certificate for my caravan quotes a MIRO of between 1250 and 1410kg to cover variances due to factory-fitted options, etc. There is little doubt that proportionately similar variances occur in noseweight. I don't see much benefit of a manufacturer quoting a noseweight of, say, 60 to 90kg in the sales brochures.

 

[TheTravellingRooster]

Whereas publishing MTPLM, shipping length, body length etc. doesn't pose a problem, variables such as MIRO and noseweight can only be quoted for guidance purposes only in any literature. As I mentioned before, the registration certificate for my caravan quotes a MIRO of between 1250 and 1410kg to cover variances due to factory-fitted options, etc. There is little doubt that proportionately similar variances occur in noseweight. I don't see much benefit of a manufacturer quoting a noseweight of, say, 60 to 90kg in the sales brochures.

Hi Lutz and to all following this interesting (purely my opinion, off course) topic.Now-Now-Now Then Guys & Gals there would appear to be an item of detail that is on the affore mentioned certificate that is held by Lutz ;that is not on my Registration Certificate.I assume that to be the CRiS Touring Caravan Registration Document (ref CVR 6).Perhaps I need to seriously consider a return to Spec Savers (yes I am one of those that upto now didn't have a problem) or could my cop-out be that my document is an original from 2001 and is out of date/in need of updateing when presented/re-issued over the telephone for change of registered keeper.My registration document has no mention of MiRO on it at all,nor indeed any weight or dimension values.

 

[Lutz]

I'm afraid you have overlooked the fact that I live on the Continent where the caravan is registered, taxed and insured in the same way as a car (with its own V5c equivalent and own number plate). My reference to registration documents therefore has nothing to do with CRIS.

 

[ProfJohnL]

Hello Taveleler,

Nose load is not rocket science, and every tower should be aware of the regulations ,and the limits of their tug and trailer.

Ignorance is no defence in law.

If you are embarking on caravanning for the first time, you should be reading up about all the facets of towing law and best practice before setting out on the road. That should include nose load, and how to measure it and trim it. There are plenty of sources of information and suggestions.

I do agree there are a lot of new things to take on board when starting to tow, but that a fact of life, and there are many other activities where certain basic rules and regulations need to be understood before you can join in with impunity, so why not caravanning?

If newbies don't know about nose loads, then that is their own fault, If the manufactures were to publish a working nose load figure, we know its going to be wrong so it would be highly misleading to do so.

Some manufacturers DO publish nose loads, but they are only ex-works values, where they have control of the condition of the caravan.

Your story illustrates the folly of not personally checking the nose load before travelling.

 

[TheTravellingRooster]

Hello Taveleler,

Nose load is not rocket science, and every tower should be aware of the regulations ,and the limits of their tug and trailer.

Ignorance is no defence in law.

If you are embarking on caravanning for the first time, you should be reading up about all the facets of towing law and best practice before setting out on the road. That should include nose load, and how to measure it and trim it. There are plenty of sources of information and suggestions.

I do agree there are a lot of new things to take on board when starting to tow, but that a fact of life, and there are many other activities where certain basic rules and regulations need to be understood before you can join in with impunity, so why not caravanning?

If newbies don't know about nose loads, then that is their own fault, If the manufactures were to publish a working nose load figure, we know its going to be wrong so it would be highly misleading to do so.

Some manufacturers DO publish nose loads, but they are only ex-works values, where they have control of the condition of the caravan.

Your story illustrates the folly of not personally checking the nose load before travelling.

Hello Prof John L,Who is this (Taveleler) New Member of the CaravanTalk forum? and where can I locate some of Their/His/Her input into our most educational and yet on occassions quite cutting daily banter ?.

 

[TheTravellingRooster]

Hi to you all,I am sorry for taking up Valuable Space with the above Double Entries,there was a Glitch on the site and I ended up Posting Twice!!?.

 

[TheTravellingRooster]

I'm afraid you have overlooked the fact that I live on the Continent where the caravan is registered, taxed and insured in the same way as a car (with its own V5c equivalent and own number plate). My reference to registration documents therefore has nothing to do with CRIS.

Hi Lutz,I cannot have overlooked the fact that you live on the Continent (unless I need an Urgent Visit to Specsavers)I have not seen anywhere in this Subject Posting to the effect of your base/living area preference.
However, I am indeed now educated(Thank You)to some of the detailed difference between your Caravan Certificate and My MiRO Certificate.
The scary thing is that this is very likely to be THE NEXT IMPOSITION from Brussels & coupled to the likely notion (another forum)that when I reach 70yrs of age (5yrs 27days away) I may be to old and doddery to be allowed to drive,never mind pulling a Mobile B&B.
We are thinking of upping sticks and taking car and caravan to The Costa Blanca,I know that I can only retain my UK plate for a limited time (and it is a Personalised one),what about the caravan needing a paperwork change of recognition?.