Paul Dodd

In some ways the legislation for this already exists, in our Current construction and Use requirements. For example how many kids do you know who get their first car and equip it with an exhaust that you could live in, and can barely here the stereo above. C and U reg 54 says 54 (2) Every exhaust system and silencer shall be maintained in good and efficient working order and [shall not after the date of manufacture be altered] so as to increase the noise made by the escape of exhaust gases. They still pass the MOT, it is therefore the testing regime that is not adequately equipped to deal with this. Police can't measure noise at the roadside and neither can an MOT station. My guess is that so long as the parts used are approved, IE Lights etc then there will be no problem. Companies that already modify cars and vans etc, have to do it in conjunction with the original manufacturer and then gain type approval. Any one making their own structural changes to a vehicle would need to do it conjunction with the OEM and then get it approved, if its going on the road that makes sense doesnt it? I havent looked too deep into how it may affect you guys, but there are always "get outs", quite often age related, and more often than not, Military vehicles were were exempted from the regs in the first place. It would be interesting to explore some specific concerns, and look at them against the legislation. Again it all comes down to Safety. Incidentally I recently did some work for one of the UK Fighting vehicle manufacturers. In the cab is a big Yellow sticker saying "Caution Armoured Fighting Vehicles can be Dangerous" ............ really ? I will try to find the photo.

The turntable on a drawbar trailer is not a Dolly, these are defined in one piece of legislation ( I cant remember which bit atm) but basically a Dolly is a trailer in its own right (and as such needs Type approval), in Agricultural use it is a device used for the interconnection of a Semi trailer with a Tow vehicle, as such it supports a proportion of the trailer load (there is a limit) and it should be designed to accomodate that load IE over 750kg it needs brakes etc. On the road a Dolly is only supposed to be used for recovery purposes, (IE You cant use it to tow your Impreza to a track day) , on its own it does not need brakes just for recovery, if a dolly was to be used as a trailer then the car or what ever is attached to it then form a trailer, as such if the combination is over 750kg , then the trailer and the road wheels of the car which are touching the road need to be functioning. If you used a Dolly to connect the Tow vehicle to a trailer , then by rights the Trailer would then become a Semi trailer, and as such would need to have continuous brakes. You then get into the requirements of , suspension, ABS and EBS. .....Minefield

There are Electric braking systems available, but as yet I havent seen any approved for use here (The EU rules allow them by the way). Problems in approval I have seen are, Usually they do not incorporate the Parking or breakaway function required by the legislation, and because they tend to take a feed from the brake light feed of the towing vehicle the reaction time does not comply. However I would say that in operation from what I have seen they are quite impressive and dont think it will be long before we see them here.

The Options would be as you say a continuous train system either Pneumatic, or Hydraulic. Electric is an option (US and Australian caravans etc ) but it is not favoured, and would be difficult to get through an approval due to the reaction times etc. Hydraulic is often used on Agricultural vehicles but again it is difficult to maintain the required retardation forces and as such Agricultural vehicles with hydraulic brake trailers should be limited to 30KPH. Pneumatic is the favourite, so if you are towing with a truck that is air equipped it shouldnt be a problem. A land rover or similar would present problems. As for Width and Length, a trailer can be up to 2.55m width (2.6 if it is refrigerated) , if the Tow vehicle is under 3500kg then the length is limited to 7m excluding the drawbar. If the Tow vehicle is greater than 3500kg then 12m excluding the drawbar (It must have a min of 4 wheels). The overall train length must be no more than 18m

Just a bit of an update for anyone interested. If you are building a Turntable steer trailer like the one in the photograph above, when it comes to braking they are not allowed (and haven't been for some years) to have Over-Run (inertia) brakes (UNECE Reg 13), this means that they cannot be Type approved and also shouldnt be able to gain an IVA or SVA. This may also mean that the driver of a vehicle equipped in this way that is stopped could be prosecuted.

When you are considering lateral protection (Sidebars) any existing bodywork and or equipment such as fuel tanks, lockers etc can be taken into consideration, so long as it meets the general requirements of the directive.

He may well find it very difficult to register a trailer in Germany. To register the trailer has to be constructed in accordance with the type approval requirements (remember they have been following these rules in most of mainland Europe for a long time) , trailers which were originally were exempted from this requirement (and the C & U regs ) such as goverment or military vehicles, prove exceptionally difficult to get through as th construction methods used dont always suit normal road use. It is likely that the Authorities will require the trailer to be modified in accordance with the latest regs, so it can comply before issueing registration. I am not aware of any exceptions in the legislation that allows exceptions for historic vehicles , but if there is I would be pleased to know.

Thanks for the feedback, glad to be of some help. Dont get put off by the Red tape, get some advice. The thing to remember about the EU legislation is that it is almost always reasonably well drafted and has taken into consideration the views of most concerned parties. The difficulty arises when the legislation appears to want to make you do something you might not think you should have to. The renegade, who ignores it or interprets it in their own way, will often "queer the pitch" for everyone else, which can often mean greater surveillance or restriction. EU rules are almost always to make life just that little bit safer. Now at risk of the next bit sounding a bit like a sales pitch, I am currently in discussion with TuV Rheinland about arranging some seminars for vehicle converters ( IE Catering trailers or exhibition units) to ensure they understand their requirements, when we know where these will be I will post details, I am sure if anyone wanted to come along, they would be welcome. Once we have done them I can post the presentation material (I will check with the Administrators first), I am also developing an interactive spreadsheet for managing the data required for a Type approval submission to the authorities (there would be a modest cost for this, and it isnt finished yet) but again when It is I will get in touch. I undertake what is called a gap analysis for my corporate clients, to assess what is and is not compliant on their vehicles, if you wanted something like this done professionally you would need to contact me outside of this site, however if you want to just get an opinion (and thats all it could be) just post a photo or PM me and I will see what I can do. Maybe if there is enough of a requirement I could create a guide, if that would help. So, all the best, and dont let the legislation keep you awake at night. No actually thinking about it , it is the best cure for insomnia I know of.

I realise this is an old thread, but for people still reading it I thought I would try and put the record straight. I work with the type approval legislation and assist manufacturers to comply, its quite complicated but I will try to illustrate it with some likely scenarios. Firstly the Type Approval Directive (or more correctly collection of directives) brings all EU members into line. If you are the manufacturer of an existing range of trailers you will have until the 29th of October 2012 to ensure the vehicle is tested and compliant, otherwise legally you cant sell it. If you design a new trailer today it has to be compliant straight away (this has been the case since 2009) before you can place it on the market. As most of you wont be manufacturers in your own right (I am making assumptions) and are probably only going to manufacture a trailer for your own use, and/or modify a trailer you buy, it is unlikely that you will go down the Whole vehicle type approval route, instead you will go for the National Small series approval (NSSTA), or Individual Vehicle approval. Both of these are less technically demanding than the Whole vehicle approval but will still require you to provide Technical data and have the vehicle tested by VCA and/or VOSA. Scenario 1 You build a trailer from scratch. In most cases you will be using components from well known manufacturers, Couplings from Bradley, Drawbars from Alko, etc etc, these are what are known as seperate technical units and will have their own approvals, your job here is to ensure that you select the right component for the job and collect the approvals together in your own "manufacturers " file for presentation to Swansea so it can be tested against this "dossier" by VOSA. You will also need to make sure you comply with all the relevant parts of the directive and provide info on each to show how you have done it. And yes this does include drawbar calcs but they are quite straight forward. If you want a list of what you need to comply with let me know. Scenario 2 You buy a trailer that is already approved, but you need to modify it. If the modifications do not affect any of the existing approvals you dont need to do anything, so for example if you buy a box van and you equip it with racking and a portable toilet (for arguments sake) you're Ok. However if you put a couple of glazed windows in it, you will have to ensure that they are subjected to approval. If you have a flatbed and want to move the rear lights you can only move them to a position within the orignal manufacturers approval, otherwise they have to be reapproved. Scenario 3 You buy an old trailer (pre type approval) but refurbish it with new lights and coupling etc, you must replace these units with type approved devices, but at the moment as this would be seen as a repair it would not require approval. I could go on , but I am sure if you bothered to read this far you are bored now. Its difficult to be spepicific whilst generalising, but the bottom line is that you shouldnt be put off self building if you are prepared to do it right, and frankly if you are not prepared to do it right , should you be on the road. Incidentaly the living van above looks great, I dont know how much it weighs (obviously has to be under 3500kgs) but you may run into some problems with roadside spot checks by the likes of RDW in Holland etc as it was manufactured after 2009 and probably doesnt have a plate on it, Indvidual vehicle approval gives some protection against this (even though it is only good for the UK) and it may be worth getting it done. Lighting is always a dead giveaway, I cant see on the photo but it should have Reversing lights etc, I have experience of being stopped with a 16oo kg trailer in Holland without reversing lights a few years ago.

Hi, I have a general interest in these sort of things, not an Owner, or a hobbyist but I value being able to go out and see the sorts of things the members on here preserve. I mainly deal with UK and EU legislation , Type approval is what brought me to this site, if I can help I will, I dont wnat to see the efforts of ordinary people thwarted by ill conceived rules and regulations. Keep up the good work.