Plated weights question

[Surfer]

Does the plated weights MIRO & MTPLM have any legal standing in law as the MTPLM seems to be a phrase only used in the caravan industry. There is no reference to it in the Road Traffic Act or Construction and Use.
Also it seems that the plated weight that VOSA would check is the one on the caravan chassis which would be completely different to the plated weight on a caravan. However I don't think there is any legal obligation to have a plate on a trailer that is non commercial as I can only find reference to commercial trailers.
Any thoughts on this and can you back up with any links to relevant legislation.

 

[Martin24]

I think Sir Stagger, I'll leave that one for the prof!!

 

[Raywood]

As I understand it the MTPLM is the maximum weight the caravan manufacturer believes is safe for that caravan. If you exceed this the caravan could be regarded as overloaded and you could be prosecuted. If you believe that it is too low the manufacturers can usually increase this although there may have to change the wheels or have some other work done, that is assuming the manufacturer is still available.

 

[colin-yorkshire1]

hi all,
Good question "Sir Stagger" I have allways been of the oppinon that the MTPLM was the maximum legal weight allowed and gone to extraordinary lengths to make sure this is adheard to. however from recent events regarding a friends boat I am not so sure.
not to go into the whole saga, it appears the law interprets the unit as trailer and load,
so what is the trailer? and what is the load?
in the case of a boat/trailer the trailer is well the trailer the boat and engine is the load plus any bits and pieces carried in the boat or on the trailer.
a caravan however could either be a trailer in its own right with all the bits attached to it like mover. spare wheel ect and the user payload awning ect as the load in this case the MTPLM is indeed the maximum weight allowed.
OR if the chasis is the trailer and the bodywork + contents is the load in which case the trailer chasis plate is the correct maximum,
and MTPLM minus noseweight just a guide.
this is important because as I now understand it. the three governing weight isses are 1. maximum gross vehicle weight, 2. vehicle rear axel load, 3. maximum trailer weight,

 

[ProfJohnL]

The NTTA publish a guide:-

http://www.ntta.co.uk/downloads/SafeLegalTowingShort.pdf
which states on page 39

Quote
"Identification plates:

1982 regulations demand that all trailers, including unbraked ones, must be clearly marked with their maximum gross weight in kg. This may be checked at any time by the police at a weighbridge.

Since 1st January 1997, all unbraked trailer plates must show the year of manufacture.

To comply with the D.o.T. Code of Practice for the recall of defective trailers less than 3500kg G.V.W. it is desirable that a trailer should carry a manufacturer's plate clearly showing:

• Manufacturers name and address chassis or serial number and model number
• Number of axles
• Maximum weight per axle maximum
• Nose weight of coupling
• Maximum gross weight (G.V.W.)
• Date of manufacture"
End quote

The purpose of the data plate is to enable the police or VOSA to have an on vehicle indication of the GVW/MAM/MTPLM. This enables them to check to see if the trailer is overweight when it is checked on a weighbridge. There is no practical need as far as the Police or Vosa are concerned for the MIRO or MIS for trailers to be given.

Consider:-
If a post 1982 trailer did not carry a data plate with its GVW/MAM/MTPLM, then the authorities would have no reference to be able to check to see if it is over weight. Failure to display the data is an offence.

As an aside issue, It is legal to employ a data plate gives a lower value of MAM/GVW/MTPLM. This may make a trailer towable for a driver with a restricted licence. However if you actually exceed the reduced weight of the data plate (even though it may be within its original value) you are committing an offence.

If you need the specific regulations that govern this subject area, then I suggest you contact any of the Department for Transport, VOSA or the NTTA.

 

[Lutz]

The problem is that the wording of UK law has not yet been brought into line with the EU directives which are actually referred to in UK Road Vehicle Construction and Use Regulations.
UK law refers to 'unladen weight' and 'maximum allowable weight' whereas the regulations talk about 'mass in running order' and 'maximum technically permissible laden mass', respectively.
Strictly speaking, unladen weight is understood to be dry weight, i.e. without any water, oil, fuel, etc. whereas MIRO includes all water, oil and a 90% fuel tank as well as 75kg for the driver and sundry items. Maximum allowable weight and MTPLM are, however, one and the same.
I have approached the Department for Transport asking for clarification and they replied that their interpretation of 'unladen weight' has changed in line with Construction and Use Regulations, i.e. with MIRO and that the wording of the law will be changed accordingly some time in the future.
In the case of cars, Section 4 item G in the V5c certificate quotes Mass in Service which is the same as Mass in Running Order. I don't why these two terms are used to describe the same thing. Item F.1 talks about Max. Permissible Mass, which, of course, is the same as MTPLM.
The actual texts of the Road Vehicle (Construction and Use) Regulations can be found under http://www.legislation.gov.uk/all?title=road vehicle construction and use regulations. However, there are lots of amendments so it's quite a task to find all the details in question.
Of course, a caravan is a trailer. It is also a vehicle, although obviously not a motor vehicle.
By the way, the term 'kerbweight' is not used anywhere, neither in UK law nor in the Construction and Use Regulations nor in EU Directives.

 

[colin-yorkshire1]

hi all,
got that,
but here is the rub, WHO is the trailer manufacturer ALKO that make the chasis and plate it according to it's maximum weight.
or the van manufacturer that later uses the chassis to build the van on (ie the trailer load) and add a further plate showing miro and mtplm, despie the legistlation there seems to be a difference.

 

[Lutz]

The trailer manufacturer is always the caravan manufacturer, not the chassis manufacturer. It is the caravan manufacturer that takes full responsibility for the end product. He is also responsible for whole vehicle type approval that is now required for new trailers/caravans.. For example, it is quite possible that a caravan is plated at 1400kg although it is built on a 1500kg chassis. In that case, it's the 1400kg that counts, not 1500kg. (That is why it is sometimes possible to ask for a caravan to be replated with a higher MTPLM without any technical modifications being necessary).
The same applies to motor homes. It is not Fiat, Ford, VW or whatever that is the manufacturer, but the company that has carried out the conversion to the end product. The V5c certificate will document this so the picture is a bit clearer here. On the Continent, where caravans are registered in the same way as motor homes, their vehicle documentation will reflect the same.

 

[RayS]

Perhaps I could re-submit a question I asked some time ago as it seems relevant to this thread, concerning the plates on imported caravans.

Can anone (Lutz ?) throw light on the load plate fitted to my 2005 MY Burstner caravan.
The handbook is a poor translation and devotes more space than how to arrange the cushions to form the double bed than anything else. To put it politely it is unclear about weights and does not include an illustration of the plate which you might expect.
The plate is as follows:
Top line: Burstner Company address
Next line 1500 kg
Next Line blank
Next line 1. 1500kg
Next line 2. 100 kg

Am I correct in assuming the 1500 refers to MIRO and the 100 to user payload, giving MTPML of 1600kg ?
If not, I do not see the point of quoting 1500 twice.
Would appreciate any input.

 

[Lutz]

Ray,
From the information given, 1500kg is the MTPLM and also the maximum permissible axle load. Hence, the reason for it being shown twice. There is no requirement to show MIRO on the plate, so 100kg will refer to the maximum permissible noseweight.
(100kg payload would be extremely low and I wouldn't consider such a low payload to be commercially acceptable.)

 

[ProfJohnL]

Hello Ray,

I had declined to answer your earlier post beacaus I was not sure how the Burstner data plate was structured, But I had concluded it was as Lutz has just confirmed.

Just a note which might be of interest to you.

Whilst both the MTPLM ad the maximum axle load are 1500Kg, you can never actually go that high on the axle, because you must also account for the nose weight within the MTPLM.

The minimum nose weight you are allowed to have is 25Kg, but that is impractically low for a 1500Kg caravan, 4% of MTPLM is a more practical value which is 60Kg so the maximum practical axle load should not exceed 1500-60 = 1440Kg. although the figure will vary with actual nose loads.

 

[Surfer]

According to the Road Traffic Act, rules, regulations etc only trailers that er being used for commerical purposes or with a GVW of over 3500kgs are obliged to have a plate fitted so it seems even the NTT cannot get it right.
It seems there is no law requiring a UK caravan to have any plated weights whatsoever!

 

[Lutz]

While the Road Traffic Act itself may not make any mention of trailers used for non-commercial purposes to be plated, it is more than likely that the Construction and Use Regulations do and these also have legal significance. I have tried to find a related reference in the regulations, but there are so many amendments that it would probably take a day to find the passage in question.
Certainly, with the introduction of vehicle type approval for caravans, which is now already in effect for new caravans, a plate is necessary as it carries information on the authority which issued the type approval.

 

[ProfJohnL]

There may be some confusion here to do with the word "plate".

In the UK it has a special meaning when related to commercial vehicles. It is a government issued device that is used for purposes of taxation and Goods Vehicle Operating licences. It also does enable the authorities to check the vehicles actual weight against its lawful load limits at a weighbridge.

It should not be confused with manufactures data/serial number. identification plate used on domestic trailers.

The Commercial Motor website carries an informative piece.

I suggest you look here:-

http://www.commercialmotor.com/legal/weights-and-dimensions-vehicle-plating.

 

[Surfer]

Seems all these so called motoring organisations interpret the law to suit thie members in a lot of cases. I also can find no reference that a manufacturer is oblige to have fitted a plate showing weights etc unless it is a commercial trailer or the trailer has a maximum gross weight over 3500kgs. I also did a search on the VOSA websites. Basically you cannot get done for overloading yoru caravan, but can get done for being a danger to other road users, i.e. tyres not suitable for weight.

 

[Lutz]

Did you wade through the Construction and Use Regulations and all their amendments? If plates were not required for caravans they wouldn't be required for cars, either, and that just can't be so. What goes for cars also applies to trailers unless specifically excluded.

 

[Raywood]

The whole thing seems confusing but the moral is that you exceed the plated weight at your peril.

 

[Lutz]

I've found the respective requirement in the EU Directive which is referred to in UK Construction and Use Regulations. The text is as follows:

This Regulation lays down rules for the EC type-approval of the manufacturer’s statutory plate * and for the vehicle identification number *. It forms part of the implementation of the Regulation on the general safety of motor vehicles.
Types of vehicles concerned
This Regulation applies to vehicles of category M, N and O, namely:

• motor vehicles designed and built for the carriage of passengers and having at least four wheels;
• motor vehicles intended and built for the transportation of goods and having at least four wheels;
• trailers (including semi-trailers).

Requirements for the manufacturer’s statutory plate
Each vehicle must be fitted with a statutory plate that shall consist (at the manufacturer’s discretion) either of:

• a rectangular sheet of metal;
• or a rectangular self-adhesive label.

The manufacturer’s statutory plate must contain certain items of information, including:

• the manufacturer’s company name;
• the vehicle type-approval number;
• the vehicle identification number;
• the technically admissible laden masses.

Requirements for the vehicle identification number (VIN)
The manufacturer must affix a VIN on each vehicle and ensure its traceability for 30 years. The VIN consists of:

• the world manufacturer identifier (WMI);
• the vehicle descriptor (VDS);
• the vehicle indicator section (VIS).

It must be affixed in an accessible position and be visible. It must be stamped so as not to disappear under normal conditions of use of the vehicle.
Provisions concerning EC type-approval
The vehicle manufacturer must submit an application for EC type-approval to the competent authority. The application must contain certain items of information, in particular:

• the brand and type of vehicle;
• the position and method of attachment of the manufacturer’s statutory plate;
• the location of the VIN.

If the competent authority deems that the vehicles complies with all requirements concerning the manufacturer’s statutory plate and the vehicle identification number of motor vehicles, it shall grant EC type-approval and issue a type-approval number pursuant to Directive 2007/46/EC.

 

[Gafferbill]

......this question was answered correctly by the Prof on June 30th.

UK regulations drafted in1982 and still in force, require that all trailers, including unbraked ones, must be clearly marked with their maximum gross weight in kgs.
This clearly covers caravans and seem staggering simple to understand to me

 

[Surfer]

Thanks Lutz however it goes back to MTPLM and whether that plate can be used as evidence of overloading. As per Lutz's post plated weight should be on the trailer which is in essence the caravan chassis as the chassis is made by ALKO and not the caravan manufacturer. The caravan is the load the trailer is carrying. Therefore if the MTPLM of the caravan is for example 1500kgs, but the GVW for the chassis is 1800kg, if you are stopped and you are weighed at 1600kg technically you are not ov erwweight for the trailer.

PS Lutz can you supply a link to the info so I can bookmark it? Thanks.

 

[Lutz]

Surfer,
Here's the link to the above information:
http://europa.eu/legislation_summaries/internal_market/single_market_for_goods/motor_vehicles/motor_vehicles_technical_harmonisation/mi0072_en.htm
If you wade through the Construction and Use Regulations you should find reference to the same EU Directive.
Like I said before, it's always the plate belonging to the final product that counts, as applies to motor homes, too. For example, you may find a Fiat plate on the chassis, but a Swift plate on the motor home. In that case it's information on the Swift plate that counts, not that what Fiat quote. The V5c certificate will also show Swift as the manufacturer, not Fiat. The same goes for trailers/caravans.
It is quite possible that, for some technical reason or other, the caravan manufacturer does not consider the product safe if the chassis is loaded to the limit that the chassis manufacturer has specified. For example, tyres of a load carrying capacity may be fitted that would be adequate for the quoted MTPLM but not enough for a higher maximum permissible chassis load.

 

[Surfer]

Thanks Lutz!

 

[TheTravellingRooster]

Hi Surfer. The term MPTLM is the caravan terminology for maximum/gross weight,that is to say the heaviest that a particular caravan can be. Consideration must also be given as to how that weight is distributed between axles & hitch-head or axle & hitch-head.
MiRO is the unladen weight as supplied from the manufacturers with/without certain essential items but as listed in the detail of the caravan as newly supplied.
If the maximum permitted weight of a caravan is exceeded it is likely that an offence will be pursued by the Road Traffic Police under the guidance of VOSA. It is VOSA that will pull a suspect caravan and tow-vehicle over but it is the police that will prosecute.
This is however subject to advisories and shifting/manipulation of the excess load at ther point of being hauled over and can often be taken no further.
There are mobile VOSA Check Points and the Motorway based locations that serve for all senarios of being subjected to a scrutiny.