DRAFT - 11th April 2013


Nine years on from my last update (April '04 see latter pages) and we are now more confused than ever.
The reason for this confusion is the new European braking regulations due to take effect in November 2014.

Our understanding of the reason for this change is nothing whatsoever to do with cars being towed behind motorhomes, it is to regulate the braking specification of a certain type of commercial trailer. All over Europe, including the UK, there are large trailers with an unusual axle layout. They are generally used for outdoor exhibitions or in Europe for displaying at town markets. The unusual layout is an axle right at the back of the trailer and a swivel/dolly axle at the front with a fold up draw bar fitted with an overrun/ inertia braked coupling. These trailers can be over 20 feet long and have a gross weight up to 3500kg. They can be towed by a medium length panel van or 4 x 4 and in the event of a serious traffic incident the trailer 'could' try to overtake the towing vehicle (jack knife). and here lies the problem. At the point of the trailer being at 90 degrees to the van/4 x 4, the overrun/inertia coupling would not be able to transmit any braking effect to the trailer brakes - this is the reason the regulations are changing. New trailers built after November 2014 must use a braking system that does not rely on the principle of overrun / inertia, the weight of the trailer bearing on the coupling and operating a simple mechanism to transmit a movement to effectively apply the trailer brakes. The new regulations state that any trailer with more than one axle, and if the axle centres are positioned more than 1 metre apart, may not be fitted with an overrun / inertia braking system. Sadly, this is where we get dragged into the issue, of course, the axles on any car are more than 1 metre apart, we cannot avoid the new regulation, although it is not aimed at cars on towing frames.
It will not affect single axle trailers at all, and shouldn't effect twin axle caravans, boat trailers, box trailers or car trailers, as their axles are normally just within the 1 metre requirement.

So why are we still confused ? A few years back, a company came into the towing frame market offering an all new braking system which avoided the need for the towing frame to have a heavy braked coupling attached to it. This was a great advantage to some as it made the towing frame much lighter and easier to manage, the problem with this new system was the cost to manufacture and install. At that time, overrun systems were very much cheaper than the new systems and still are today. Over the past few years other systems have now come onto the market and are generally referred to as 'electronic braking' systems. The big question is ; will they comply with the new regulations in Nov'14 ??

The most important point is how do these systems achieve their 'slowing down' sense, how do they tell the car's brake pedal how far to travel to achieve proportional brake effect ? The new European regulations clearly state that overrun / inertia is not acceptable. This is a simple mechanical transfer of the inertia related to the weight of the trailer to provide proportional braking by creating a movement at the front of the braked coupling and operating a lever to 'pull' the trailer brakes on. Are any or all of these systems using inertia in any way to provide the sense for how hard to apply the brake pedal in the car ?

The 'electronic braking' companies have been telling motorhomers their systems will comply with the new regulations, some have said their systems are Type Approved throughout Europe. This has lead motorhomers to believe they can travel anywhere in Europe and have no fear of being challenged by police. Not correct. Neither Type Approval or compliance with a future European standard will convince a Spanish police officer who plans to extract a fine from a motorhomer who is 'flat' towing a car. The Spanish issue is covered later in this update.

They have introduced terms such as 'dead pedal', suggesting that small car brakes will not work efficiently without a vacuum servo working in the car's braking system. Again, Not correct. A simple point - do caravans or car trailers have a vacuum servo ? Of course not, and their brakes work efficiently because the inertia applied to the braking system is in proportion to the weight of the trailer, in the case of a towed car, this will apply much more pressure than we could easily apply with an average human foot, the servo simply allows a driver to push the pedal with reasonable effort. The servo does not improve the dynamics of the car's closed braking system in any way.

In my opinion, the 'electronic braking' suppliers are responsible for the latest round of confusion, they have had to create reasons why motorhomers should pay the high prices for their systems over the relatively cheap overrun systems which have been tried and tested over many years. OK, we now have to accept the days are numbered for overrun / inertia systems due to the new regulations, but in recent years Car-A-Tow and other overrun type manufacturers have faced a relentless slating by the new boys trying to find ways to justify their expensive products.

I can only speak for our product, CAR-A-TOW introduced its folding towing frame to the UK market 23 years ago in 1990, at this time the only frames on the market were chain or strap on recovery frames. Since then we have sold over 7,000 towing frames, including over 1000 in France, and in recent months 6 in Belgium, 5 in Holland, 8 in Italy and even 4 in Germany. Sales are very strong in France and our 7 fitting agents are very happy with the product and the rapidly rising interest from French motorhomers.
CAR-A-TOW will introduce a conforming towing frame system when the new regulations have been made completely clear. We see no need to introduce a new system, and unfortunately a new pricing structure, until the new regulations are in force and the final specification is completely clear.

Our information is the new regulation for Nov 2014, is not retrospective, any overrun / inertia system produced and sold prior to Nov'14 will be permitted to be used for years into the future, and of course the same will apply to any of the current electronic braking systems.
To repeat my earlier point, are any of them using inertia anywhere in their system ?

I still cannot bring this to a conclusion as I am waiting for a meeting at the Department for Transport in London to try to get the final details and a statement from them. CAR-A-TOW will make this information available just as soon as it is received from the D f T.

And now onto Spain - ugh ! In over twenty years, not once have we; motorhomers, ever received an offer from a club or magazine to get involved and try to sort out the problem in Spain - do they not listen to their members or readers, are they not aware that an awful lot of motorhomers want (and in many cases need) to flat tow a car into Spain and not have to use a heavy and expensive trailer?
Of course they are.

We need their help, motorhoming needs their help.......but nothing, other than repeatedly stating it is NOT LEGAL in Spain.........WRONG.........what is not legal in Spain, and elsewhere in Europe, is one motor vehicle towing another motor vehicle. We are already aware of this, if your car breaks down, you are not permitted to tow it on a rope or chain, any broken down vehicle must be professionally recovered, this seems to be the case anywhere in Europe.
But that isn't what we are doing, the car hasn't broken down, we are towing a trailer. It is not illegal to tow a trailer in Spain, but if a Spanish region chooses not to accept the car as a trailer then that is the issue to be addressed.

Our clubs and magazines could make a big difference if they were to become involved in the problem, instead of just brushing it aside and accepting the ill informed views and money grabbing (fines) attitudes of certain police officers in North Eastern Spain.

Even the British Consulate in Alicante has just rolled over and trotted out the standard answer that towing a car in Spain is illegal. We at CAR-A-TOW have asked them to take this up with the Spanish authorities and challenge the lack of understanding that the car fitted with a towing frame is a trailer. The answer comes back that they are unable to become involved in interpreting Spanish law, if the consulate is there to help to 'look after' British citizens why won't they help motorhomers ? We are trying to press this further with that Consulate and hope for more success in the future. We will also now move on and try to get more cooperation from our Embassy or other agencies in Madrid. It isn't the law that's wrong, it's the understanding of it by their own officers and authorities !!

We have a copy of a Police ticket which has been professionally translated and states:

This will not be sorted out until British and other European motorhomers get together and 'encourage' the Spanish to rethink what they are doing. This is where the clubs and magazines should organise a campaign, along with their European counterparts to work on the Spanish.

Let's see what WE can do to finally get things moving.

Alan Bee - CAR-A-TOW - 01202 632456 - info@caratow.com

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For those who like the idea of towing a car behind a motorhome - the good news continues.
For those who've always been against it - the continuing good news is probably not so good.

Over the years there has been a great deal of rumour and misunderstanding concerning the legality of towing frames.
As the proprietor of CAR-A-TOW and designer of the Car-A-Tow Towing Frame System, I, along with stalwart motorhomer Terry Nash of W. Sussex, (I actually think that Terrier Nash would be more appropriate), managed to bring the controversy to a satisfactory conclusion a few years ago now.
He (Terry) had eloquently badgered every government department associated with motor vehicles and trailers, to finally get them to give us some definitive answers back in Jan/Feb 2004.

The Department for Transport stated :
" When an A frame is attached to a vehicle (e.g. a motor car) and towed by a motor vehicle (e.g. a motorhome) we believe the A frame and car become a single unit and as such are classified in legislation as a trailer "
" We believe the use of A frames to tow cars behind other vehicles is legal provided the braking and lighting requirements are met".

At that time, The D f T expressed concern about a car's braking performance without its engine running.
" if the braking system has power assistance (i.e. servo or full power) it is likely that this assistance will be required during towing to meet the required braking efficiency"

At CAR-A-TOW, we are only concerned with small cars, suitable for towing behind a motorhome, generally up to around 800/1100kg kerb weight, and fitted with servo assisted brakes, (vacuum assistance).
CAR-A-TOW carried out braking performance tests on a broad range of modern small cars, he results have proven conclusively these cars not only meet the required performance for trailers - 50% braking force in relation to its maximum weight - but in most cases far exceed this requirement, without any vacuum assistance from a servo.
An important point to consider:
On a small car, a Vacuum Servo does not increase braking effect at the wheels, it is designed to make the brake pedal easier to push for all shapes and sizes of driver - less effort to achieve the required performance. A 6ft 6inch weightlifter would have no problem operating the brake pedal on a Ford Fiesta without the assistance of a vacuum servo.
Trailer overrun braking (inertia brakes), as fitted to the CAR-A-TOW system, relies upon the momentum of the weight of the trailer to exert force on the overrun coupling to activate the simple lever to pull on the brake cable to operate the trailer's brakes.

If the motorhome brakes gently the trailer brakes are hardly required, if the motorhome brakes hard the weight of the car/trailer exerts it's force on the overrun and brakes hard - proportional braking without the vacuum servo assistance.
A further point raised by The D f T ; the ability of the motorhome/car combination to be reversed without operating a manual mechanism.
Contrary to common belief, the regulations do not state that braked trailers must be fitted specifically with " auto reverse brakes ".

The D f T remind us :
" From 1st October 1988 the inertia braking system (overrun) is required to allow the trailer to be reversed with the towing vehicle without imposing a sustained drag and such devices used for this purpose must engage and disengage automatically "

Although we understand the meaning, the regulation does not state specifically 'auto reverse brakes', as commonly fitted to modern trailers and caravans, but requires a system to enable a trailer to be reversed without the need to manually operate a mechanism.
There are specific regulations concerning this requirement and the Car-A-Tow frame system can meet the requirements as stated in UN-ECE Regulation No. 13, Annexe 12, Page 137, Paragraph 3:4 and 3:5, providing the system is fitted and operated correctly and is in good condition.

The D f T state :
" Where technical requirements are mandated then the burden falls to manufacturers to ensure products meet the requirements "

We are happy that the Car-A-Tow system does comply and does meet the requirements as stated, this has been demonstrated to various experts and can be repeated as often as required.
Yet another misunderstanding is that 'trailers' may not be fitted with hydraulic brakes, the correct regulation is that trailers may not use a hydraulic parking brake. Cars are fitted with a mechanical parking brake (handbrake) and providing this handbrake lever can be operated from the ground, i.e. with feet on the ground, this handbrake conforms to trailer requirements and is completely legal.
The D f T have also stated :
" The trailer would not have to be tested to establish that it did meet the requirements - no test facilities are available" !!!!!
The D f T has reminded us continually over the years that they do not have the final say. Whilst they have now stated their belief that A frame towing is legal (after years of suggesting it was illegal), they also remind us:
" it is for the courts to make definitive interpretations of the law"
We are not aware of a court expressing a view either way. The main point here, in relation to towing a car behind a motorhome, is that we now have a statement from the D f T that they believe a car on a towing frame is in legislation etc etc a trailer providing it conforms to all other regulations relating to trailers.

If a British court was forced to question the basic principle of whether or not a car is considered to be a trailer, when connected to a towing vehicle with a towing frame, it is our understanding that a court would look to the relevant government department - The Department for Transport - for guidance and opinion, that department has already stated they believe it is classified in legislation as a trailer and it is legal.

We rest our case !!
So……. After all those years of batting this backwards and forwards with the D f T (formerly The D of T), where does this leave us ?

The D f T have confirmed they now believe that towing a car with an A frame is legal provided etc etc

We have proof that we can meet trailer braking requirements and performance although

The D f T have stated that testing is not required and

The D f T have stated that no test facility is available anyway

We have a conforming parking brake

We have a conforming breakaway system (for cars below 1500kg)

The lighting conforms

We carry the registration plate of the towing vehicle (covering the rear plate of the car)

That's it then, can we now stop all the nonsense both spoken and printed, about the so called 'A frame debate', hook your car on the back and just enjoy your holidays !

Alan Bee

Anyone who wishes to challenge any points made here, is invited and welcome to contact TOWCentre Ltd with details of which aspect of A frame towing they consider is not legal.

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