Towing in Spain

[Melvin Hutchinson]

Can anyone tell me the rules for towing in Spain, I wish to take a small car with me as I want to spend the winter there, can you tow with a braked trolly dolly or do you have to use a braked trailer B-) B-) B-)

[Derek Uzzell]

Do you really mean "a braked trolly dolly" (which is something normally used only by recovery services), or just a common-or-garden braked A-frame?

[Mel E]

The Law in Spain, as in most of the rest of the EU, bans towing on A-frames (or trolleys) except at very low speeds, specifically for vehicle recovery to the nearest practicable garage. EU Law, however, allows temporary importation (max of 6 months) into any EU country, of a vehicle that is deemed legal in its own country. It is on this basis that UK motohomers tow cars on A-frames to Spain (and through France where it is equally illegal for French registered vehicles). HOWEVER, if you have followed the debates about A-frames on this Forum (do a search if you haven't) and in the pages of MMM, you will find that A-frame towing is of dubious legality in the UK. Until someone is taken to court, and legal precedent established, it is impossible to be clear about this - the problem arises because English Law operates on a fundamentally different basis from most Continental Law, which is based around Napoleonic Law. Thus, even thoough trailer law is now uniform across the EU, it is still possible for a different interpretation to apply under English Law compared with Napoleonic, which is the basis of Law in France, most Latin countries, and Germany and elsewhere. My advice would be to use a trailer, preferably twin axle. If you must use an A-frame, make sure you always have a second driver, in case you are stopped, fined, and have to drive the two vehicles separately. Do NOT use a towing dolley: this is definitely illegal in the UK and the rest of Europe, except for recovery (which is limited to 40mph on m'ways and lower speeds elsewhere!)

[olley]

Hi one of the RV guys uses a dolly all the time, never had any problems, guess it's a case of the cops having better things to do. Olley

[Dave Newell]

Hi all, I'm sure this debate over A frame legality is going to rumble on until someone gets taken to court but for now here is the content of a Dept of Transport fact sheet regarding the issue. It is quite long so I'm sorry about that but as I read it A frames definitely don't meet the requirements to be legal. D. "FACT SHEET-------------- October 2005. Note on A-Frames and Dollies: When an "A" frame is attached to a vehicle (e.g. a motor car) and towed by a motor vehicle (e.g. motorhome) we believe the "A" frame and car become a single unit and as such are classified in legislation as a trailer. As a consequence the car and A-frame are required to meet the technical requirements for trailers when used on the road in Great Britain. These requirements are contained within the Road Vehicles (Construction and Use) Regulations 1986 (SI 1986/1078) as amended (C&U) and the Road Vehicles Lighting Regulations 1989 (SI 1989/1796) as amended (RVLR). Trailers having a combined axle mass not exceeding 750kg are not required to have brakes fitted. However, if the trailer (regardless of mass) is fitted with a braking system, then all brakes in that system must operate correctly. The regulations do not include design constraints on how this should be achieved but, for example, it could be met by direct linking of the trailer brakes to the brake system of the towing vehicle or by automatic inertia (overrun) operation via the towing hitch. Inertia systems can only be used for trailers with a maximum combined axle mass of 3500kg. Regulations 15 and 16 set out the braking requirements - including minimum braking efficiencies for trailer brakes. Subject to certain age exemptions, the regulation requires the braking system to comply with the construction, fitting and performance requirements of European Community Directive 71/320/EEC along with its various amending Directives. The most recent consolidated directive is 98/12/EC. Alternatively the braking system can comply with the corresponding UNECE Regulation No.13.09. In addition, C&U Regulation 18 requires the braking system to be maintained in good and efficient working order. If the brakes of the towing vehicle do not directly operate the trailer brakes the use of an inertia (overrun) system is acceptable. If the trailer braking system has power assistance (i.e. servo or full power) it is likely that this assistance will be required while in motion to meet the required braking efficiencies. This is because once the vacuum reservoir is depleted it is possible that the brakes will not meet the braking efficiency. To prevent the trailer being used illegally a remote vacuum pump, powered from the tow vehicle, could be installed to recharge the reservoir, alternatively a source could be made available from the tow vehicle. From 1 October 1988 the inertia braking system was required to allow the trailer to be reversed by the towing vehicle without imposing a sustained drag and such devices used for this purpose must engage and disengage automatically. This will be very difficult to achieve on an A frame using an inertia (overrun) device. Other provisions from Regulation 15 and Regulation 86A of C&U require the fitting and use of a secondary coupling system in which the trailer is stopped automatically if the main coupling separates whilst the combination is in motion. Alternatively, in the case of trailers up to a maximum mass of 1500kg, the drawbar must be prevented from touching the ground and the trailer able to retain some residual steering. Whilst being towed, trailers are subject to the relevant requirements given in RVLR, including the use of triangular red reflectors. There would be further requirements for the display of the appropriate number plate, etc. The use of dollies is intended for the recovery of broken down vehicles, not for the transportation of a vehicle from A to B. Under Regulation 83 of C&U a motor car is permitted to tow two trailers when one of them is a towing implement and the other is secured to and either rests on or is suspended from the implement. Therefore as a trailer, if the maximum laden weight of the dolly exceeds 750 kg it must be fitted with operational brakes, additionally the brakes on the wheels of the second trailer (the towed car) must work and meet the specified requirements. Again this would be very difficult for the rear brakes of a motor car, on their own, to meet the 50% braking efficiency required for a trailer. The dolly would also be required by Regulation 22 of C&U to be fitted with suspension. Regulations 19 and 22 in C&U permit a broken down vehicle to be recovered without complying with these requirements. However, there is further legislation under the Road Traffic Act that introduces a limitation on the maximum speed that the combination can be driven; this is 40mph on motorways and 20mph on other roads. We do not supply copies of legislation but I have included some information on various sources where they can be obtained. If you would like to purchase printed copies of Statutory Instruments these are available from TSO: The Stationery Office Tel: 0870 600 5522 PO Box 29 Fax: 0870 600 5533 St Crispins e-mail: HYPERLINK "mailto:book.orders@tso.co.uk" book.orders@tso.co.uk Duke Street online ordering: HYPERLINK "http://www.tso.co.uk/bookshop" www.tso.co.uk/bookshop Norwich NR3 1GN Alternatively you can consult The Encyclopaedia of Road Traffic Law and Practice published by Sweet and Maxwell. This publication is updated regularly and is available in most city reference libraries. EU Directives can be found at: HYPERLINK http://europa.eu.int/eur-lex/en/search/search_lif.html http://europa.eu.int/eur-lex/en/search/search_lif.html UN-ECE Regulations can be found at: HYPERLINK http://www.unece.org/trans/main/wp29/wp29regs.html http://www.unece.org/trans/main/wp29/wp29regs.html From the above I hope it is clear that we believe the use of "A" frames to tow cars behind other vehicles is legal provided the braking and lighting requirements are met. However, while this is our understanding of the meaning of the Regulations, it is only the Courts which can reach a definitive interpretation of the law. If you require any further information regarding the regulations covered by this fact sheet, please contact the DfT at the address below: Transport Technology and Standards 6 Department for Transport Zone 2/04 Great Minster House 76 Marsham Street London SW1P 4DR Telephone: 020 7944 2078 Fax: 020 7944 2196 alison.alleyne@dtlr.gsi.gov.uk TTS.enquiries@dft.gsi.gov.uk"

[olley]

Hi Dave not saying that they are legal, just that people are using them and plod is not interested. Regarding this sentance: "From 1 October 1988 the inertia braking system was required to allow the trailer to be reversed by the towing vehicle without imposing a sustained drag and such devices used for this purpose must engage and disengage automatically. This will be very difficult to achieve on an A frame using an inertia (overrun) device" Pro-tow point out that the regulations don't state a minimum distance that you have to be able to reverse, and that the DVLA do not have any test facilitys to check what a "sustained drag" is or how to measure it. So simply being able to reverse against the spring pressure of the hitch seems to meet the regulations. Could be why plod's not interested, as a good lawer could drive a coach and horse's through the reg's. Olley

[david lloyd]

[QUOTE]olley - 2006-07-26 2:30 PM ...as a good lawer could drive a coach and horse's through the reg's. Olley[/QUOTE] Aaah - but could he reverse an A-frame? I've said all along Olley that the regulations can be met - but can everybody do it? Regards, david

[Dave Newell]

Very true Olley but for how long? One day someone will get stopped and perhaps prosecuted but until then we'll all just carry on in blissful inorance I suppose. D.

[olley]

blissful ignorance, now that I can do B-) Olley

[Brian Kirby]

This subject does come up again and again. 

Please could Mr Moderator put a sticky on Dave Newell's excellent abstract from DoT and Mel E's comments on legality?

It seems that a constant and authorative point of reference might be of great assistance by getting enquirers quickly to the ground rules.

In the end, possibly where an accident has closed a road and the police direct traffic to turn round to clear a backlog, someone with a car on an A frame will discover that they can't execute a relatively simple reversing manoeuvre while the police watch. 

That's when the funny stuff will probably go into the fan! 

Ignorance as a defence: forget it!

[Mel B]

Somehow I think the police would have enough to deal with directing the traffic away from the accident and wouldn't care less about your vehicle and trailer set-up! Supposing someone sometime does have to prove that a car on an 'A' frame CAN be reversed ... Mel E - are you open to offers to demonstrate your ability to do this???

[Mel E]

Olley, PC Plod might not be interested in your friend's towing dolley set-up, but his insurers will be if he is involved - even as an innocent third party - in an accident. Let me repeat, so there can be no ambiguity: - A-Frame towing is of doubtful legality, for two reasons: 1. It relies on the conversion turning the car into a trailer to which trailer law and not car law applies, and there is nothing to say this is correct (which is why the continentals ban it under Napoleonic Law interpretation) 2. Trailer Regulations require the towing vehicle/trailer combination to be capable of being reversed under control. - Towing dollies are DEFINITELY ILLEGAL (i.e., there are phrases in the relevant Regulations banning their use) except for recovery of a broken-down vehicle at very restricted speeds. Mel B, I certainly don't claim to be able to reverse a car on an A-Frame, even though I have done so for a short distance. I believe, having studied the actual wording of the relevant Regulations, that it is virtually impossible for the average driver to meet the letter of these regulations. But, hey, Olley seems quite happy to drag a thoroughly illegal rig at totally illegal speeds through our dense traffic, so why bother with the law? (Sorry, was it Olley's friend - I got very confused after 2 or 3 of the postings?). Whoever it was, this is totally typical of the 'I'm alright Jack, so b****r the Law' attitude that gives us all a bad name, but is, unfortunately, all too typical today!! In repeat: towing dollies are ILLEGAL, except for specific vehicle recovery situations at very limited speeds. ALL, Do be aware that Dave's very useful posting is the contents of comments by the DforT. As such it refers to the appropriate Regulations without actually quoting them in full. Thus there is lot more to the 'reversing' requirements than they have mentioned - they have only dealt with the aspect (braking efficiency of the towed trailer) that was raised in the original question posed to them. All trailers, including caravans, deal with the reversing issue expicitly by having special wheel hubs that 'switch off' the brakes when the wheels go backwards. The hubs are thus built for a specific side of the towed vehicle and muct not be swapped over. Clearly a car on an A-Frame cannot do this, nor can the rear wheels of a car on a towing dolly. Hence, when reversing, the brakes will be fully applied - just one of the revesing problems!

[olley]

Hi Mel, you said: But, hey, Olley seems quite happy to drag a thoroughly illegal rig at totally illegal speeds through our dense traffic, so why bother with the law? (Sorry, was it Olley's friend - I got very confused after 2 or 3 of the postings?). Whoever it was, this is totally typical of the 'I'm alright Jack, so b****r the Law' attitude that gives us all a bad name, but is, unfortunately, all too typical today!! In repeat: towing dollies are ILLEGAL, except for specific vehicle recovery situations at very limited speeds. [unquote} You’re wrong I don't actually know the chap, just seen him do it. I agree that it’s illegal, no question of that. I actually tow using a Brian James trailer, but to my mind an "A" frame is safer, (lower centre of gravity) and easier to set up, it's only drawback is reversing, but then from comments on here and other sites, most people can't reverse a trailer anyway. Sorry don't really understand your "I am alright jack" do you never speed, never break any laws yourself? Pulling a car on an "A" frame is hardly a hanging offence; it’s just a case of the law not catching up with progress. The brakes coming full on while reversing is a bit of a red herring. Unless you are trying to reverse up a kerb the spring or hydraulic damper on the hitch will prevent the brakes coming on. I blame the police and DVLA for not going to court immediately "A" frames where used, as they should have done over "do you need a "C" license over 7.5 tonnes" then we would all know exactly what the law was. Olley

[Brian Kirby]

But Melvin asked about the "rules".  That has to be interpreted as meaning what is legally permissible.  Our learned friends have given exemplary answers on this above.

However much people want to use A frames, or believe that the law will eventually catch up with practice, until the law is actually changed the legality of using these devices is unclear, but at best dubious, in this country.  Their use by UK citizens (or whatever we now are) in other countries where they are illegal, could be legal only if it were actually legal to use them in UK.  Most of Europe works on the opposite legal concept to UK.  We take the view that if it isn't banned, it is legal.  Their view is that if it isn't legal, it is banned.  Therefore, if you're nicked abroad you have no defence, you can't prove in their legal system that what you were doing is, in fact, legal in UK.  It will do you no good at all to say "I believe these are legal in UK, you prove they aren't."  Your Eurocop will merely say "no, they are illegal here so you must prove they are legal in UK."  And that, you can't do.

Re reversing.  Of course, if you meet a tractor in a narrow lane and can't reverse your rig all that will happen is you'll have an interesting exchange with the tractor driver about your driving ability!  However, if you run into an emergency situation where the police (or fire brigade, or other emergency service) require you to back up and turn around and you cannot, because your vehicle will not reverse as required, it seems to me they will (understandably) become ratty.  Under these circumstances, unlikely as they may seem, with you causing unecessary delay, they may well take note that the vehicle and not the driver caused the problem and subsequently issue a summons.  Besides, overrun brakes will engage under many circumstances, not just when encountering a kerb.  For example reversing uphill, or when unevenness, for example potholes, are encountered, and so on.  All the world is not flat and smooth - at least the bits I visit aren't!

What you're left with is real a risk: whether or not you take it is up to you!

[david lloyd]

Brian In the extreme circumstances you describe, if I were unable to reverse out of the situation, I would simply unhitch the car and turn it around. Something I have seen done with trailer caravans (whose drivers' could not reverse properly) when presented with a similar situation. After over 20 years on the emergency ambulance service I can honestly say that the emergency services will be more concerned with dealing with the incident than worrying over the legality of your vehicle combination and, in all likelihood, would help to unhitch the car and turn you around rather than try and deal with something that cannot really be resolved at the scene. The rules still stand - if the trailer, and how it is operated, complies with trailer law then it is legal in this country. Best regards, david

[Mel B]

Mel E .. you've upset me now, there was I holding you up on a 'pedestal' in total awe of your wonderful skills ... and you had to go and shatter my illusion! Can't a girl have a dream?

[Dave Newell]

Yes David, you ar quite correct: "The rules still stand - if the trailer, and how it is operated, complies with trailer law then it is legal in this country." Sadly no A frame towbar rig I've ever seen complies fully with trailer regulations and therefor ethey are ILLEGAL to use in this country! "If the trailer braking system has power assistance (i.e. servo or full power) it is likely that this assistance will be required while in motion to meet the required braking efficiencies. This is because once the vacuum reservoir is depleted it is possible that the brakes will not meet the braking efficiency. To prevent the trailer being used illegally a remote vacuum pump, powered from the tow vehicle, could be installed to recharge the reservoir, alternatively a source could be made available from the tow vehicle. From 1 October 1988 the inertia braking system was required to allow the trailer to be reversed by the towing vehicle without imposing a sustained drag and such devices used for this purpose must engage and disengage automatically." I can't think of a single car currently being produced that doesn't have servo assisted brakes and i have yet to see an A frame towing system that includes a vacuum supply of any kind (other than leaving the engine runnin on the towed car) to the towed car's brakes. D.

[Brian Kirby]

If everyone seems to be against you perhaps you are going in the wrong direction!

Funny how these little signature tags have caught on isn't it?  How do you plead, David? 

At the moment you do somewhat appear to be in the position you describe! :-)

[david lloyd]

Brian I'm not quite sure - I see lots of people arriving at the shows towing cars in the same direction. Dave, I accept the theory of the vacuum brakes etc - but in practice (and demonstrated by ProTow frames repeatedly) the brakes still do reach the required braking efficiency apparently. Regards, david

[Dave Newell]

David, I'm intrigued as to how Protow demonstrate braking efficiency of a car with no servo asistance while it's on an A frame. Can you describe their demonstration please? D.

[Brian Kirby]

[QUOTE]Dave Newell - 2006-07-28 11:27 AM David, I'm intrigued as to how Protow demonstrate braking efficiency of a car with no servo asistance while it's on an A frame. Can you describe their demonstration please? D.[/QUOTE]

Dave

It'll probably work on demo, while the "trailer" vacuum reservoir still has some suck, but unless the reservoir is evacuated each time the brakes are applied, that will soon run out.

Anyone ever tried stopping a car with servo assisted brakes when the servo has failed?  Basically, you can't!  Even on a level road at about 15mph, and pulling on the steering wheel for greater leverage on the brake pedal, it just doesn't work!

The tow vehicle must end up doing all the work with no contribution from the towed vehicle.  Should lead to lots of fun if your braking coincides with a patch of ice!!

[Dave Newell]

Hi Brian, "Anyone ever tried stopping a car with servo assisted brakes when the servo has failed? Basically, you can't! Even on a level road at about 15mph, and pulling on the steering wheel for greater leverage on the brake pedal, it just doesn't work!" Yes I have, several times! A few years back I was employed as a driver/mechanic for a local courier company with a fleet of mainly transits. These were notorious for the vacuum pump drive to sheer off from the back of the alternator leaving no servo assistance. I had to drive one van back from Paddock Wood in Kent to Telford in Shropshire after this happened, boy did I get good at looking ahead and slowing using the gears so that I didn't have to use the brakes very often. They do work without servo assistance but it takes about ten times (or at least that's what it felt like) the pressure on the pedal without the servo toget the same braking effort at the wheels. The worst vehicle I drove with failed servo asistance was my old Freight Rover 310, the brakes were abysmal with the servo, despite having four pot front calipers, but when it failed it really scared me. When I did finally bring it to a halt I couldn't get out for ten minutes cos it took that long to persuade me bum to let go of the seat!! D.

[david lloyd]

[QUOTE]Dave Newell - 2006-07-28 11:27 AM David, I'm intrigued as to how Protow demonstrate braking efficiency of a car with no servo asistance while it's on an A frame. Can you describe their demonstration please? D.[/QUOTE] Hi Dave I confessed earlier to not having much knowledge of the theory of mechanics so I am unable to explain in any detail just how this was done. However, when deciding whether to use a trailer or tow on an A-frame I looked at all the arguments and spoke to various suppliers of A-frames. ProTow were, in the end, my preferred choice after discussing the various points with them. At the time Alan Bee, designer of the ProTow frame, published an open letter regarding the legality of his A-frame (I say his A-frame because, as we all know, not all A-frames are the same) and covered this aspect of concern re: braking efficiency when the engine is not running. His letter states: "At ProTow, we are concerned with small to medium cars, suitable for towing behind a motorhome, generally up to around 800/1100kg kerb weight, and fitted with servo brakes, (vacuum assistance). ProTow frames have carried out braking performance tests on a broad range of modern small cars, the results have proven conclusively these cars not only meet the required performance - 50% braking force in relation to its maximum weight - but in most cases far exceed this requirement, without the need for servo assistance." I have not reproduced the letter in full, which goes on to elaborate on other issues such as "auto reverse brakes", but I am sure copies are available from ProTow frames - tel 01202 632456 - for anyone who is interested. So, I have not witnessed these tests and I know that these are the claims of a commercial concern. However, sometimes we have to make purchasing decisions based on the information available to us. For example, I drive a car that Toyota say is safe and meets all the necessary regulations - albeit I have a duty to ensure that the vehicle, and how I operate it, continues to meet those regulations. Similarly, we have a motorhome that both Renault and Knaus assure me complies with the relevent legislation - but I have neither witnessed the tests carried out on either vehicle nor received copies of the results of any such tests. I don't think the issue of whether brakes do work without servo assistance is in question, after all, you state that they do yourself in a later posting when you describe driving an earlier model transit van without the servo working. I am sure that, as braking technology has progressed since then, braking efficiency without the servo has also improved. My own experience since towing the car has also supported that view in practice. Hope this helps illustrate my point of view but I also hope this doesn't run and run.... Best regards, david

[peter.maniac]

Hi I thought a "trolley dolly" was an air hostess so i guess this must be an air hostess with brakes! Peter

[Dave Newell]

Hi David, I only asked because you said that Protow "demonstrated repeatedly", I don't consider a letter from someone trying to sell the equipment much of a demonstration. I could write an open letter saying that I'm the King of Cuba but it doesn't demonstrate the point at all. Regarding brakes working without servo assistance, yes they will work. A brief mechanical history lesson here; In the early days of motoring we had drum brakes all round, front wheels were fitted with a system called twin leading shoes. What this meant was that the fixed hinge point for both shoes was on the trailing end in forward rotation direction and the moving end of the shoe is on the leading end. This gives what is called a "self servo action" inn that as theshoe contacts the drum it is pulled into tighter contact. The wheel cylinders that moved the shoes were relatively small diameter. Fast forward to the advent of disc brakes and because the braking material is now clamping across the sides of a revolving disc more force is required from the hydraulics which is why the hydraulic cylinders on disc brakes are much larger than those in drum brakes. Anybody who can remember drivng early disc braked cars with no servo will probably remember the hard pedal. So the vacuum servo was employed to give greater hydraulic pressure (over 1 Tonne per square inch under emergency stop conditions) and useable brakes. If you take the servo assistance away the brakes still work but it takes a lot more force on the pedal to give the same braking effort. Now the A frame systems I've seen fitted all connected to the brake pedal at least halfway up it's length which means they don't even use the full leverage of the pedal. I personally find it difficult to beleive that a car with this setup can meet the 50% required braking efficiency. But I'm prepared to be proved wrong. I still haven't seen an A frame setup that fully complies with trailer law. Regards, D.