Why was European Type Approval introduced?
The introduction of Directive 94/20/EC came under the umbrella of the European Whole Vehicle Type Approval. The reason for this was to create free trade of both vehicles and components throughout the whole European Community. This means that consumers can rest assured that providing the tow bar was manufactured to comply with 94/20/EC specifications, the product will have been manufactured to a specified quality and technical standard, regardless of its country of origin.
What are the consequences of fitting a non EC Type Approved Tow bar?
Directive 94/20/EC became compulsory under EU legislation in 1998. If your vehicle was registered from August 31st 1988 or onwards and you are using a tow bar that does not conform to Directive 94/20/EC you will be taking certain risks. Insurance cover may be affected; there is also the potential pitfall of prosecution under the Construction & Use Regulations Act, as well as safety issues due to using an unapproved product. If in doubt contact PF Jones who will be able to advise you. Search National Stockists to find your local specialist.
I own a small sized trailer that I only tow on the odd occasion; does my tow bar need to EC Type Approved tow bar?
It is imperative that your tow bar conforms to Directive 94/20/EC irrespective of whether you actually use it for towing or not! An uncertified tow bar is an infringement of the Road Traffic Act. Simply having an unapproved tow bar fitted to your vehicle is an offence, even if you never use it for towing!
If I fit it myself, could I transfer a non EC Type Approved tow bar from my 1996 Honda Civic to my Civic which was registered after 1st August 1998?
NO. It is mandatory that vehicles registered after 1st August 1998 are fitted with Type approved Tow bars.
To conform to Directive 94/20/EC would I have to fit a swan neck tow bar as supplied by the manufacturers?
The towball and two-hole flange ball faceplate can be manufactured by an independent producer while still being EC Type Approved. Witter have an extensive range that will cover most vehicle applications. The range encompasses over 250 products.
I own a Audi TT and a small trailer. I can’t find a supplier that seems to list a tow bar for my vehicle, could one be made to order?
No. The manufacturer never declared the vehicle as fit for towing at the time it was Type EC Approved. The Audi TT has no mounting points or specified towing capacity. If this vehicle was registered on August 1st 1998 or thereafter and is fitted with a tow bar you will be liable for prosecution.
Is my new vehicle or model variant EC Type Approved for Towing?
The answer can always be found on the VIN (Vehicle Identification Number) plate. This is usually situated under the bonnet, but can vary between models. Stamped on the lower edge will be four figures that specify the vehicle’s carrying capacity. These are as follows: Vin No – or chassis number
---- Kg – This is the Maximum vehicle weight
---- Kg – Maximum train weight which consists of both trailer and vehicle
1. ---- Maximum front axle load
2. ---- Maximum rear axle load
If there is no specified train weight the vehicle has not been approved to use for towing and it is illegal to do so. If you find the specified train weight of your vehicle, your towing weight will be the train weight minus the maximum vehicle weight.
Is it compulsory to have my tow bar fitted by an authorised specialist, or can I fit it myself?
If you strictly adhere to the instructions while fitting your tow bar you are able to fit it yourself. As installing the towing electrics can be a convoluted and sometimes tricky process, you may want to opt for the full installation of the tow bar to be carried out by a PF Jones.
How do I know if a tow bar is EC Type Approved?
An EC Type Approved product will have a stamp, label or data plate displaying an E No. For example:
E11 - signifies that this product was EC Type Approved in the United Kingdom.
0001 - is the approval number.
This is actually the very first EC Approved UK tow bar for the Ssangyong Musso and this is a Witter Type Approval.
I want to buy an ‘S’ registered Vectra. It already has a non Type Approved tow bar fitted. What do I need to do?
Before you buy this vehicle you must insist that the vendor replaces the tow bar right away with an EC Type Approved product. If the vendor refuses to fulfil their obligations you should report this to your local branch of the Trading Standards Office.
The tow bar on my ‘P’ registered BMW 318is is not EC Type Approved, but the vehicle is EC Type Approved and it was UK registered in January 1997.
Could I legally tow my trailer or caravan to France using this vehicle?
You could. Although these EC regulations were introduced in various countries and at various times, they are implemented differently depending on the country in question. The country in which the vehicle was registered dictates when and how the vehicle complies with the EC Regulations.
If I use a non EC Type Approved tow bar on the continent and I have an accident while towing, could I be prosecuted?
No. You will not be liable as long as your vehicle was UK registered prior to the 1st August 1998. Issues will only arise if your tow bar was inadequate, was installed incorrectly or if it was of an inferior quality. In this instance the tow bar could have contributed towards the cause of an accident. This is why it is important to ensure that a quality product is properly fitted.
Is it true that that my warranty will become invalid if I don’t fit the manufacturer’s tow bar?
Your local motor dealer may tell you that fitting a Type Approved Witter tow bar will invalidate your vehicle’s warranty, but this is definitely not the case. The purpose of Directive 94/20/EC was to facilitate free trade. EC Block Exemption Rules specify clearly that the manufacturer of a motor vehicle cannot prevent components that are deemed to be of an equal quality to be fitted or supplied by a franchised outlet. This includes all appropriate EC Type Approved tow bars.
Can an EC Type Approved tow bar be fitted with a ‘drop plate’?
Yes, but this is only the case for a tow bar that has been tested and submitted as using a ‘drop plate’ for EC Type Approval. Witter tow bars for Mercedes M Class, Mitsubishi Shogun, Land Rover Defender, Discovery, Range Rovers and various 4WD and off road motor vehicles have all been subjected to rigorous testing to ensure their suitability. Contact PF Jones who will be able to offer further advice.
Is it possible to fit a stabiliser or cycle carrier between the tow ball, faceplate and tow bar if I use an EC Type approved tow bar?
Yes, Witter tests their tow bar’s with a 25mm minimum spacer between the tow bar and the tow ball.
Must the tow bar and tow ball have a separate EC Type Approval and have a Type Approval number?
No. There is a specified part number for the tow ball and this means that it has been approved and tested as one of the components of the tow bar. Each tow ball has an identification code of Z11. This is stamped clearly within the Witter Logo’s outline on the flat top section of the tow ball.