a question from another forum, why do caravan manufacturers continue to affix the number plate above the 1300mm legal height limit thus exposing their customers to a fine and loss of demerit points and allowing the caravan to be deemed defective.
In SA its because there's no inspection before granting registration, it's self regulation meaning the manufacturer/dealer is the one who makes the decision about compliance. Don't know about other states.
When I arrived to pick my den up the office girl was away at the rego place (VIC) getting my van registered. The van was sitting in the dealers yard without plate on it, mmmmmmm.
Needless to say my plate was 200mm too high so had to change it only a few moons back.
So many vans out there, new or old, with number plates too high and some strange attitudes with them.
-- Edited by Dougwe on Friday 27th of November 2015 02:42:21 PM
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In SA its because there's no inspection before granting registration, it's self regulation meaning the manufacturer/dealer is the one who makes the decision about compliance. Don't know about other states.
Dave
The law states quite clearly that by affixing a compliance plate to a vehicle the manufacturer certifies that - THE VEHICLE COMPLIES WITH ALL APPLICABLE ADR's AS AT THE DATE OF MANUFACTURE STATED ON THE COMPLIANCE PLATE.
No one else has responsibility for this function.
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Why is it so? Professor Julius Sumner Miller, a profound influence on my life, who explained science to us on TV in the 60's.
The matter of height of number plates on vehicles is not a vehicle manufacturers issue; likewise it is not a dealer issue. The responsibility of compliance with regards the height of the number plate is something that is subject of individual State Legislation and something that REQUIRES compliance by the registered operator of the vehicle and not otherwise. For example, the relevant law in Queensland is as follows......
Transport Operations (Road Use ManagementVehicle Registration) Regulation 2010 Part 3 Vehicle registration
30
Transport Operations (Road Use ManagementVehicle Registration) Regulation 2010 Part 3 Vehicle registration
[s 30]
(ii) if the vehicle is a vehicle other than a vehicle mentioned in subparagraph (i)2 number plates displaying the assigned number.
Position, visibility and legibility of number plate
(1) The registered operator of a vehicle must ensure that each number plate issued for a vehicle is permanently attached to the vehicle so that, if the vehicle is on level ground
(a) the number plate is (i) in an upright position parallel to the vehicles
axles; and (ii) not more than 1.3m above ground level; and
(b) unless an accessory plate is attached to the vehicle in the way required under section 37the characters on the number plate are visible from 20m away at any point within an arc of 45o from the surface of the number plate above or to either side of the vehicle, in the way shown in figures 1 and 2 at the end of this section; and
(c) any cover on the number plate
(i) is clear, clean, untinted and flat over its entire
surface; and
(ii) has no reflective or other characteristics that would prevent
(A) the successful operation of a photographic detection device; or
(B) the number plate from being legible; and
(d) the number plate is in a clearly legible condition, including being clearly legible from any position from which it is required to be visible.
Maximum penalty40 penalty units.
(2) A load on the vehicle is taken to make the characters not visible contrary to subsection (1)(b) if the load
(a) makes the characters not visible or only partly visible; or Current as at 1 September 2015 Page 33
Transport Operations (Road Use ManagementVehicle Registration) Regulation 2010 Part 3 Vehicle registration
[s 30]
(b) obscures the characters.
(3) The registered operator must also ensure that
(a) if the vehicle has been issued with 2 number plates1 number plate is attached to the front of the vehicle and the other to its rear; or
(b) if the vehicle has been issued with only 1 number platethe number plate is attached to its rear.
Maximum penalty12 penalty units.
(4) The registered operator does not contravene subsection (1)(a) or (b) if
(a) it is not practicable to attach a number plate to the vehicle in the way required under subsection (1)(a) or (b) because of the vehicles construction; and
(b) the registered operator attaches the number plate to the vehicle as nearly as practicable in the way required under subsection (1)(a) or (b).
(5) The registered operator does not contravene subsection (1)(b) if the position for the rear number plate of the vehicle (the towing vehicle) is obscured by another vehicle (the towed vehicle) being towed by the towing vehicle and any of the following applies
(a)
(b)
the towed vehicle is registered under this regulation or a corresponding law to this regulation, and displays its rear number plate in the way required under subsection (1) or under the corresponding law;
the towing vehicle is a tow truck, the towed vehicle is not registered under this regulation or a corresponding law to this regulation, and the towed vehicle
(i) (ii)
displays the towing vehicles rear number plate in a way consistent with the requirements of subsection (1); or
displays an accessory plate for the towing vehicle in the way required under section 38(5);
Page 34
Current as at 1 September 2015
Transport Operations (Road Use ManagementVehicle Registration) Regulation 2010 Part 3 Vehicle registration
[s 30]
(c) the towing vehicle is not a tow truck, the towed vehicle is an exempt vehicle under section 4(a), (b) or (l) when being towed by the towing vehicle and the towed vehicle displays the towing vehicles rear number plate in a way consistent with the requirements of subsection (1) or under a corresponding law to this regulation.
(6) If a vehicles number plates are removed and confiscated under the Police Powers and Responsibilities Act 2000, section 74H, the vehicles registered operator does not contravene subsection (1) or (3) while the number plates are confiscated.
(7) In this section number plate does not include an accessory plate issued
under section 37. photographic detection device see section 113 of the Act.
Figure 1
Current as at 1 September 2015
Don't shoot me for pointing out the legislation; I did not write it. The simple fact is that the owner is left in the lurch by the law and the law says that "ignorance is no excuse". In other words, the owner has to be aware of this legislation and abide by it.
Although the law is quite specific, one might reasonably expect that a competent dealer would also know the law and not affix number plates contrary to the requirements and in so doing leave their customers in the lurch.
In relation to the question regarding motorhomes and whether or not they are also subject to the same situation, it is simply the case that a motorhome is a vehicle and as such is subject to the same legislation. The two following definitions are of specific importance...
Transport Operations (Road Use ManagementVehicle Registration) Regulation 2010 Schedule 8
caravan means an enclosed trailer designed for people to live in.
motorised caravan means a motor vehicle designed mainly for people to live in.
In other words, a motorhome is both a vehicle and a motorised caravan.
Hope this helps with some of the confusion (ducking for cover now!) Remember, I did not write the law.
Tones
-- Edited by Tones on Saturday 28th of November 2015 10:02:33 AM
-- Edited by Tones on Saturday 28th of November 2015 10:20:21 AM
You have no argument from me, it is an ADR therefore applies Australia wide. I understand the responsibility of the van compliance is with the registered owner, the problem i have is either the manufacturer puts a number plate location point on their van as to where the plate is to be located and the selling dealer who registered the van on their clients behalf and affixed the plate at the incorrect height and at no time is the client advised that the van they purchased is deem defective and should not have been allowed to leave the sales yard and they (their clients) are now exposed to a fine and loss of demerit points (in NSW is $415.00 and 3 demerit points) and further down the road a motor vehicle inspector declines to register the van.....and the argument starts between the inspector and owner of the van stating it has always been registered from new. In some states there is a period of years before the van needs inspection for registration.
The registered owner then has to pick up the cost for the relocation of the plate and number plate light, this cost should be back charged to the selling dealer.
I am away the NSW - RMS has now required all vans exceeding a GTM of 2 tonnes now must be inspected by a heavy vehicle inspector who will inspect from a safety aspect but also from a compliance aspect unlike a car which is inspected only from a safety aspect and any heavy vehicle inspector found to allow registration of a non-compliant van could have his licence revoked.
It is interesting from an insurance point of view because the policy states that the van must comply to all requirements of the law and clearly it does not.
I understand it is not a safety issue BUT the the law clearly states this requirement for the number plate.
It is amazing how many van owners have a don't care attitude until they are booked and then complain, they should fix the problem.
FYI, in NSW there have been television articles showing the new 360 degree number plate recognition camera's being installed in all highway patrol vehicles with the capacity of checking 6 plates per second from any angle and you do not have to be mobile, you can be parked and they only have to drive down the street and the camera will pick out the vehicles that are not compliant including not registered....they say we have been warned. Our local highway patrol only have to park on one of the highways and scan the vehicles has they pass.
Well I think I have found some of the problem , well the height of the number plate of two caravan from the same maker I seen today , one had low chaise and the height was under the 1300 mm the next one had off road chasie. And was above the 1300 mm with the plate in the same place on the caravan body , so is you have a raised surpension this maybe what causes the problem.
