MTPLM upgrade

It would have been cheaper to simply remove the sticker by the door. There's no need for it.

You should also have had an amended NCC certificate

For what it’s worth. It’s not a legal document.

I thought I had resolved the matter in my mind, but on reading back over the various posts I realised that I was still unclear.  Should I:

 

(a) Apply to Swift for an uprated “Manufacturer’s Plate” to replace the one beside the door, at a cost of £50, now showing the MTPLM to be 1750kg.

 

(b) Do nothing.  If stopped by the police and found to be over the 1701kg MTPLM limit on the “Manufacturer’s Plate” beside the door, I refer the officer to the plate inside the front locker and hope that he accepts the figure on this plate.

 

So, after giving it a bit more thought, and agreeing with almost everything Lutz says above, I’m still not comfortable with the view that the plate by the door is irrelevant.   Where the legislation defines the manufacturer’s plate, there is a key phrase, highlighted in the clip below:

2.1. A manufacturer's plate, modelled on that shown in the appendix hereto, must be firmly attached in a conspicuous and readily accessible position…

To me, the conspicuous and readily accessible position is by the door, not inside the front locker, hence by the door would appear to be the place to find the manufacturer’s plate, stating the MTPLM to be observed.  The fact that a UK manufacturer (i.e. Swift, and others) chooses to put a second plate showing a higher technically permissible weight inside the front locker, instead of in a second column on the plate by the door, is – presumably – allowed.

As I've said before, the cheapest solution is to simply remove the label by the door. It doesn't fulfil legal requirements anyway. There is no need for it so long as the statutory plate is present in the front locker. Caravan manufacturers that are not NCC members won't have a label by the door anyway.

Most caravans, including imports from the Continent which do not have a label by the door, have the statutory plate located in the front locker. It is as conspicuous and accessible as the statutory plates on cars which have to fulfil the same legal requirements. Their plates are usually located somewhere on a bulkhead crossmember inside the engine compartment, so they are just as covered up as in the front locker of a caravan.

My wife suggested to me that I should look in the Swift owner's handbook for and answer (why didn't I think of that?) and this is what it states:

***********

Maximum Technically Permissible Laden

Mass (MTPLM) (Lower Limit):

The fully laden mass of the caravan in the

manufacturer’s standard specification which is

stated in the publications, technical handbooks,

brochures and weight plate and used for tow

vehicle matching.

 

MTPLM (Upper Limit):

The mass takes into account specific operating

conditions including factors such as the

strength of materials, loading capacity of tyres,

etc.

 

Upgrading of maximum technically

permissible laden mass:

The lower (or standard) MTPLM is quoted in the

Technical Handbook, in brochures and on the

caravan weight plate. However, in some cases

it may be possible to increase this to a higher

(upper) MTPLM. (See Technical Handbook for

details).

If extra user payload is required, an upgrade

maybe available (model dependant), this must

be requested via your dealer and is chargeable.

*************

So it does seem fairly clear cut that the chargeable weight plate upgrade is required.  Rightly or wrongly, I'll just bite the bullet and cover myself.

Swift are obviously oblivious of or think that they are above the law. There is no such thing in any legislation as a lower or upper limit of an MTPLM. They are not defined anywhere. A maximum is always absolute. If there is a higher limit then the lower one cannot be called a maximum unless the conditions under which it applies are different. For example, trucks which have axles that can be lifted off the ground have two MTPLMs depending on whether all axles are load carrying or not.

The manufacturer will always have the caravan type approved to the higher level.

What is displayed next to the door doesn't meet legal requirements. Manufacturers that are not members of the NCC won't apply such a label anyway.

When Swift talk about the "weight plate" they should say which weight plate they are referring to. They are obviously counting on customer's willingness to pay up for something that is totally unnecessary.

 

Just to clarify, if there are two limits, only the higher one can be the Maximum Technically Permissible Laden Mass, the other would be a Maximum Permissible Laden Mass, but it cannot be referred to as a technical limit.

Please don’t take this the wrong way Lutz. But do you work for VOSA or whatever the may be called today.

No, I used to be in product engineering in the car industry, in the group responsible for developing and approving towbars.