Portugal - Cat C1 and down rating moho weight

[Barcobird]

I have done everything by the book in line with the Brexiteers!

Obtained Portuguese residency.

Matriculated my motorhome to Portugal

Exchanged my UK license for a Portuguese one.

So everything's rinky dinky ? Well no not really. My motorhome GVW is 4500kgs on my UK license I had category C1 but because it was obtained by grandfather rights they are refusing to accept this on my Portuguese license. However I can drive up to 4250kgs here on a normal license. So I need to down grade my moho by 250kgs, its a long shot I know but any Portuguese members on here got any ideas?

[Derek Uzzell]

Are you 100% certain about being able to drive a motorhome weighing 4250kg on an ordinary Portuguese 'car' licence?

 

The reason I ask was because I remember, when EU driving licence regulations were being 'normalised' some years ago, that - due to a translation error - the Portuguese regulations initially permitted a 'B' licence holder to drive a vehicle with a 4250kg maximum weight, but I was under the impression that the Portuguese law was subsequently amended to conform with the EU 'B' licence norm of a maximum vehicle weight of 3500kg + a 750kg unbraked trailer.

 

This 2019 Portuguese forum thread discusses the 4250kg weight and the advice by "old bloke" SEEMS to confirm what I've said above.

 

https://expatsportugal.com/community/transport-getting-around-portugal/driving-licence-restrictions/

 

The Portuguese 4250kg motorhome weight was also discussed here in the last few postings of this 2016 thread.

 

https://forums.outandaboutlive.co.uk/forums/Motorhomes/Motorhome-Matters/Hitch-in-getting-van-weight-uprated/41401/

[Barcobird]

Morning Derek,

Ironic the other guys name was Peter as well (lol)

I am never 100% about anything here as the law is sometimes ambiguous and suits the fine *-)

 

This is a translated copy which as far as i know is correct.

 

In addition, the holders of Category B driving licenses over 21 years and a minimum of 3 years of qualification in the same category can drive vehicles with gross weight greater than 3500 kg and up to 4250 kg, provided that:

 

It destines exclusively for recreational purposes or social purposes pursued by non-commercial organizations;

The transport of more than nine passengers is not carried out, including the driver, or any type of goods, other than those indispensable to the use which is assigned to them.

 

Peter

[yoko8pups]

When I can get home tomorrow I can post the number of the law which permits the 4250kgs and if you go to the GNR they will confirm whether the law is still in force. I did when we matriculated my van and they said the law number was correct. I would imagine they would have to publish it in Correio de Manha if the law had been altered, or at least we would have read something somewhere. I dont have the van papers with me at the moment

[Derek Uzzell]

This Portuguese article is dated 6 April 2021 and addresses the question "I have a category B driving license. What can I drive?"

 

https://www.razaoautomovel.com/2021/04/tenho-carta-de-conducao-da-categoria-b-o-que-posso-conduzir

 

The final section reads as follows

 

E autocaravanas, posso conduzir?

Sim, desde que o peso bruto não seja superior a 4250 kg. De acordo com o Decreto-lei n.º 138/2012 acima citado, mais concretamente graças ao ponto 2 do artigo 21º, “a condução de veículos com massa máxima autorizada superior a 3500 kg e até 4250 kg pode ser exercida por titulares de carta de condução da categoria B com mais de 21 anos e pelo menos 3 anos de habilitação”.

 

Contudo, há duas obrigações a cumprir: estes veículos têm de destinar-se “exclusivamente a fins de recreio ou a ser utilizados para fins sociais prosseguidos por organizações não comerciais” e não podem permitir “o transporte de mais de nove passageiros, incluindo o condutor, nem de mercadorias de qualquer natureza que não as indispensáveis à utilização que lhes for atribuída”.

 

The relevant law can be viewed here

 

https://files.dre.pt/1s/2012/07/12900/0342603475.pdf

 

and the 4250kg motorhome 'exception' can be found in Artigo 21 on Page Number 3438.

 

The GOOGLE translation reads

 

2 — Driving vehicles with a maximum authorized mass greater than 3500 kg and up to 4250 kg may be carried out by holders of a category B driving license with more than 21 years old and at least 3 years of driving in that category provided that these vehicles:

a) Are intended exclusively for recreational purposes or to be used for social purposes pursued by organizations non-commercial;

b) Do not allow the carriage of more than nine passengers, including the driver, or of goods of any nature other than those essential for the use that is assigned to them.

 

So there's no doubt that the Portuguese up-to-4250kg-motorhome law that Barcobird has referred to above is current.

 

(The French 'Code 79' unlimited-motorhome-weight for a Category B licence is shown as a footnote on a France-issued driving licence. I don't know if there's anything similar for a Portugal-issued Category B licence, but - if not - there might be potential difficulties when driving in countries that have a rigid B licence 3500kg maximum.)

[Barcobird]

so back to my original problem of reducing the weight to 4250kgs.

 

There is a company;

 

LTA - Laboratório de Tecnologia Automóvel, Lda. That increases the weight from 3500kgs to 4250kgs but don't reduce the weight although apparently they used to. *-)

 

If I had known all of this while it was UK matriculated I could have asked SV Tech to do it!!!

[Derek Uzzell]

You've mentioned LTA and that company's website mentions increasing a vehicle's gross weight but (as you've said) not decreasing the weight.

 

https://lta.pt/pt/servicos/transformacoes

 

As it's possible to deal with a gross weight increase alteration, presumably a weight reduction change should also be possible (though it's likely to be less common).

 

When LTA told you that they can't help you with the 4500kg to 4250kg decrease, did they offer any advice on how you might proceed?

[Keithl]

Peter,

 

Have you tried contacting Pilote to ask if they can help? Possibly by issuing a new VIN plate and COC with the reduced GVW.

 

Keith.

[Derek Uzzell]

Worth a try, but the Pilote model that Barcobird owns was never marketed with a 4250kg gross vehicle weight.

[Barcobird]

Derek Uzzell - 2022-01-28 8:42 AM

 

You've mentioned LTA and that company's website mentions increasing a vehicle's gross weight but (as you've said) not decreasing the weight.

 

https://lta.pt/pt/servicos/transformacoes

 

As it's possible to deal with a gross weight increase alteration, presumably a weight reduction change should also be possible (though it's likely to be less common).

 

When LTA told you that they can't help you with the 4500kg to 4250kg decrease, did they offer any advice on how you might proceed?

 

I had several conversations with LTA and they also had copies of paperwork from me. They eventually said although it was accepted in the past IMT no longer accepted down grades but you can upgrade from 3500 to 4250kgs. Talking to IMT directly they have confirmed this, however I have not been able to find a law where this was changed so I don't know if they make there own rules or if I can challenge this. I will endeavour to dig a little deeper.

[Barcobird]

Keithl - 2022-01-28 9:11 AM

 

Peter,

 

Have you tried contacting Pilote to ask if they can help? Possibly by issuing a new VIN plate and COC with the reduced GVW.

 

Keith.

 

Its a possibility as the vehicle was originally 3500 and I asked for the upgrade to 4500kgs when ordered new.

However I'm not sure if the authorities here would accept it.

 

This is all very annoying because if the agency that did my driving license and imported the motorhome had mentioned something at the beginning I could have got the log book changed before starting the process. >:-(

[Barcobird]

Derek Uzzell - 2022-01-28 9:46 AM

 

Worth a try, but the Pilote model that Barcobird owns was never marketed with a 4250kg gross vehicle weight.

 

When I ordered it I asked for the upgraded chassis to 4500kgs.

 

Fully loaded we generally come in at 4100kgs which would come under the 4250kg and that's including a scooter in the garage.

[Barcobird]

yoko8pups - 2022-01-27 3:42 PM

 

When I can get home tomorrow I can post the number of the law which permits the 4250kgs and if you go to the GNR they will confirm whether the law is still in force. I did when we matriculated my van and they said the law number was correct. I would imagine they would have to publish it in Correio de Manha if the law had been altered, or at least we would have read something somewhere. I dont have the van papers with me at the moment

 

I presume your vehicle was under the 4250kg threshold ?

[Derek Uzzell]

Barcobird - 2022-01-28 10:15 AM

 

Derek Uzzell - 2022-01-28 9:46 AM

 

Worth a try, but the Pilote model that Barcobird owns was never marketed with a 4250kg gross vehicle weight.

 

When I ordered it I asked for the upgraded chassis to 4500kgs.

 

Fully loaded we generally come in at 4100kgs which would come under the 4250kg and that's including a scooter in the garage.

 

For the 2018 model-year all of Pilote's Galaxy (A class) motorhomes were marketed with a standard GVW of 3500kg, except for G781 designs that - due their size - were only available with a 4500kg GVW.

 

741 models could be ordered (in France and elsewhere) with a GVW of 4500kg and it's common to find 741s that were bought in the UK having the 4500kg GVW as the payload of 3500kg versions is (realistically) too small.

 

If it's impossible to get your motorhome's GVW reduced to 4250kg in Portugal, could you get a Portuguese C1 licence entitlement that would permit you to drive your motorhome at 4500kg GVW?

[Brian Kirby]

Barcobird - 2022-01-28 10:15 AM

Derek Uzzell - 2022-01-28 9:46 AM

Worth a try, but the Pilote model that Barcobird owns was never marketed with a 4250kg gross vehicle weight.

When I ordered it I asked for the upgraded chassis to 4500kgs.

Fully loaded we generally come in at 4100kgs which would come under the 4250kg and that's including a scooter in the garage.

Don't know if this might help, Peter, but this link: https://tinyurl.com/4634fbuh is to a forum string on down-plating a van. In the penultimate post I described how I was able to get our (then) Hymer down-plated via a very helpful dealer and Hymer. This resulted in Hymer altering their records of the van, plus a new, replacement, Hymer VIN plate (the same in all respects as the original plate saving for the reduced MAM), so that it appeared as though it had originally been manufactured and sold at 3,500kg.

 

I'm just wondering whether, if Pilote can't/won't down-plate your van to 4,250kg (which seems possible, as it will never have gained type approval at that weight - yes I know, 4,500 is greater than 4,250, but rules is rules!) they might be willing to down-plate it to 3,500kg (at which weight it will have been type approved)?

 

Now, before you start tearing your hair out, :-) with the van plated at 3,500kg, perhaps LTA could then up-plate it to 4,250kg?

 

Its a long shot, and a bit like scratching your left ear with your right hand, and it would involve two lots of costs but, when the Devil has the reins?

[Barcobird]

Brian Kirby - 2022-01-28 12:23 PM

 

Barcobird - 2022-01-28 10:15 AM

Derek Uzzell - 2022-01-28 9:46 AM

Worth a try, but the Pilote model that Barcobird owns was never marketed with a 4250kg gross vehicle weight.

When I ordered it I asked for the upgraded chassis to 4500kgs.

Fully loaded we generally come in at 4100kgs which would come under the 4250kg and that's including a scooter in the garage.

Don't know if this might help, Peter, but this link: https://tinyurl.com/4634fbuh is to a forum string on down-plating a van. In the penultimate post I described how I was able to get our (then) Hymer down-plated via a very helpful dealer and Hymer. This resulted in Hymer altering their records of the van, plus a new, replacement, Hymer VIN plate (the same in all respects as the original plate saving for the reduced MAM), so that it appeared as though it had originally been manufactured and sold at 3,500kg.

 

I'm just wondering whether, if Pilote can't/won't down-plate your van to 4,250kg (which seems possible, as it will never have gained type approval at that weight - yes I know, 4,500 is greater than 4,250, but rules is rules!) they might be willing to down-plate it to 3,500kg (at which weight it will have been type approved)?

 

Now, before you start tearing your hair out, :-) with the van plated at 3,500kg, perhaps LTA could then up-plate it to 4,250kg?

 

Its a long shot, and a bit like scratching your left ear with your right hand, and it would involve two lots of costs but, when the Devil has the reins?

 

Gotcha Brian could be another scenario. I have contacted Pilote today and they have replied asking for the paperwork, so they haven't said yes but they also haven't said no. Fingers crossed .

 

IMT have also come back to me today and said they would need paperwork from Pilote, so again they have not said no, yet....

Have a good weekend all. Peter

[Barcobird]

I have received the answer from Pilote and basically it’s NO.

This was there response

“ On this vehicle, we are in stage 3 of the construction: Fiat, Alko and Pilote

 

The Alko transformation( braking..) allows the maximum weight of the vehicle to be increased to 4T5.

On a Fiat without transformation, the maximum mass on a PL chassis is 4t250 or 4t4.

 

We are obliged to follow the technical characteristics of each stage.

 

In the Fiat/Alko homologation file, there are only 3 possibilities for the maximum masses.”

[Barcobird]

I assume if the vehicle was in England and I got SV Tech to do it then they would only change the registration document and metal plate.

The COC would not be altered which would then present a problem should the vehicle be exported ?

[Derek Uzzell]

The DVLA would alter the V5C registration document and SVTech would provide a plate/sticker showing the revised GVW.

 

The CoC would not be affected.

 

[Barcobird]

Derek Uzzell - 2022-02-08 3:32 PM

 

The DVLA would alter the V5C registration document and SVTech would provide a plate/sticker showing the revised GVW.

 

The CoC would not be affected.

That’s what I thought Derek, so even if I had completed this process in England the COC would not be accepted during the import process in Portugal

Peter

[Brian Kirby]

Barcobird - 2022-02-08 2:37 PM

 

I have received the answer from Pilote and basically it’s NO.

This was there response

“ On this vehicle, we are in stage 3 of the construction: Fiat, Alko and Pilote

 

The Alko transformation( braking..) allows the maximum weight of the vehicle to be increased to 4T5.

On a Fiat without transformation, the maximum mass on a PL chassis is 4t250 or 4t4.

 

We are obliged to follow the technical characteristics of each stage.

 

In the Fiat/Alko homologation file, there are only 3 possibilities for the maximum masses.”

If that is a literal transcript of their reply, it seems, (with all due respect to Pilote :-)) that there is scope for them to have misunderstood your question. The English is less than good, and in places the precise meaning unclear (to me!).

 

For instance, I do not understand "The Alko transformation( braking..) ". As I understand the normal practice, it is Fiat braking mechanisms (hubs, discs, callipers etc,) which are installed to the AlKo rear stub axles. So the Fiat mechanicals all interact with other Fiat mechanicals. Unless they have changed practice since we had ours, there are no AlKo braking components. If this is still the case, then there is no logical reason why a the braking of vehicle equipped to run safely at 4.5 tonnes, should become unsafe at 4.25 tonnes. After all, it is not banned from being driven unladen, when its actual weight would be substantially lower than even 4.25 tonnes. I just think your reply may have come from the office boy, and not the engineer! :-)

 

So, what I think they may be trying to say is that there is no extant Type Approval for your vehicle at 4.25 tonnes, so they would need to obtain the equivalent of an IVA (Individual Vehicle Approval) to make the change, and they can't be fagged! However, it seems that, in UK, this procedure can be implemented by any private individual, and whereas engineering collaboration may be required, in the case of reducing the plated weight from 4.5 to 4.25 tonnes for driving licence purposes only, it seems a bit OTT.

 

This was accepted in UK as a part of the European Type Approval procedure. In UK it is administered by DVSA (Driver and Vehicle Standards Agency) as a Voluntary Vehicle Approval, and is applicable to vehicles already registered in UK. As this was all put in place while we were in the EU, I'm assuming there should be a similar facility in Portugal. It involves a vehicle inspection, and is chargeable. I don't know who, under this procedure, would be responsible for providing the revised vehicle plate.

 

The procedure is described here, https://tinyurl.com/27dp8z35 with the downloadable application form and guidance notes in English.

 

If you could sniff out the Portuguese equivalent body (it seems the vehicle should rate as a car with fewer that 8 seats, exceeding 3.5 tonnes) I get the impression that the procedure should be fairly straightforward (give or take doing it in Portuguese!). However, it may be worth a call to DVSA in UK to check whether this could be used to down plate as you need to do, and if so, whether they are aware of their Portuguese equivalent organisation.

 

It may be a long shot, I simply don't know, but it looks a possibility. One can but ask. Hope this helps.

[Derek Uzzell]

Brian Kirby - 2022-02-08 6:10 PM

 

...If you could sniff out the Portuguese equivalent body...

 

I think Barcobird has already done that (his posting of 28 January 2022 10:05 AM above)

 

IMT= Instituto da Mobilidade e dos Transportes, I.P.

[Brian Kirby]

OK, thanks Derek. You're right, I hadn't made that connection. We all have our acronyms, and it seems a number of people get confused by them: DVLA, DVSA, VOSA, so I assume Portugal may have similar.

 

It still may be worth prodding them a bit further, as what they appear to be saying is, on the face of it, a logical illogicality! :-) Perhaps if Peter can get an explanation from DVSA as to whether this is permissible in UK, and was equally permissible before Brexit, it may jog the IMT to delve a bit deeper.

 

I can't imagine it is a regular request, so it may just be a case of "we've never done that before!" It also depends somewhat on Peter's fluency in Portuguese "regulations speak" (no slight to Peter's linguistic abilities intended - it's just that these issues tend to get clouded in unfamiliar technical jargon that not even the locals speak!), and whether he's using the right terminology to switch on the right receptors! It also depends on how approachable the bureaucrats are when asking.

 

I do just wonder whether, if Pilote can't help, AlKo can? It seems to be their chassis that is tying up Pilote, and it will have its own T/A record and chassis number. Is it possible for AlKo to confirm that the chassis will still meet their T/A approval standard if down plated to 4,250kg? If so, would Pilote then accept AlKo's written word on that, and then provide the 4,250kg plate.

[Barcobird]

Brian Kirby - 2022-02-09 11:16 AM

 

OK, thanks Derek. You're right, I hadn't made that connection. We all have our acronyms, and it seems a number of people get confused by them: DVLA, DVSA, VOSA, so I assume Portugal may have similar.

 

It still may be worth prodding them a bit further, as what they appear to be saying is, on the face of it, a logical illogicality! :-) Perhaps if Peter can get an explanation from DVSA as to whether this is permissible in UK, and was equally permissible before Brexit, it may jog the IMT to delve a bit deeper.

 

I can't imagine it is a regular request, so it may just be a case of "we've never done that before!" It also depends somewhat on Peter's fluency in Portuguese "regulations speak" (no slight to Peter's linguistic abilities intended - it's just that these issues tend to get clouded in unfamiliar technical jargon that not even the locals speak!), and whether he's using the right terminology to switch on the right receptors! It also depends on how approachable the bureaucrats are when asking.

 

I do just wonder whether, if Pilote can't help, AlKo can? It seems to be their chassis that is tying up Pilote, and it will have its own T/A record and chassis number. Is it possible for AlKo to confirm that the chassis will still meet their T/A approval standard if down plated to 4,250kg? If so, would Pilote then accept AlKo's written word on that, and then provide the 4,250kg plate.

 

Trust me Brian you won’t “jog” the IMT to do anything !!

My Portuguese is passable but I do have a daughter who is virtually native so I don’t think anything was lost in translation :-D

Last resort I can have a go at alko, nothing to lose really.

Peter

[Hans]

Yes there are ALKO breaking components. In stage 2.. The final COC is the weight class. Stage3. In case of upgrading you need a new coc.