Key elements to understand road circulation type approval for R agricultural trailers & S agricultural towed machines

DOWNLOAD the Catalogue on Categorisation of R & S

It is important to note that EU Type Approval for R&S vehicles remains optional, since these types of vehicles can continue to be homologated under national requirements. In fact, before 2016, there was only national approval for these vehicles, which led to many differences among Member States in terms of technical requirements and on the categorisation. E.g. some countries within the EU categorise slurry tankers as S, some as R vehicles.

EU type approval for R&S vehicles is possible since 2016, simplifying access to the full single market for manufacturers that wish so. Industry representatives and company experts have therefore worked together within CEMA and with other stakeholders to recommend a balanced way forward for manufacturers of trailers ‘R’ and  interchangeable towed vehicles ‘S’ to get EU type approval for their vehicles. This will allow the free circulation on the road and registration without restrictions in any Member State. The work has been conducted within the European Commission’s Working Group on Agricultural Tractors and with the contribution of all stakeholders.

Manufacturers of R&S vehicles are not obliged to go for EU type approval developments. They can also choose to comply only with national requirements if they so desire, but without benefitting from the advantages of an EU type approval.

What are important differences between R&S vehicles under EU Type Approval (Mother Regulation 167/2013) in terms of dimensions and masses ?

  • Maximum weight rules set a limit up to 10 tonnes, either per axle or total weight over the axles for both R and S category vehicles. The CEMA proposal does not introduce any change on that.
  • With multiple axles it depends on the wheelbase but with a wheelbase above 1.8 m 10 tonnes per axle is allowed. So with a triple-axle vehicle the max weight on the axles under EU type approval – for road circulation – is 30 ton.
  • Maximum width for ‘R’ vehicles can go up to 3 m like it is the case for S vehicles. R vehicles can be up to 3 m width due to the tyres and to tools needed for the functioning of the machine. However, for R vehicles, the width of the cargo area is limited to 2.55 meters.

Why are Member States so strict for EU requirements on dimensions and masses?

Member States focus on dimensions and masses in EU legislation because a vehicle that has an EU approval cannot be banned from registration and on-road use.

Additionally, for R vehicles the main reason for the 2.55 m restriction on the cargo area is the competition within the transport sector using N (truck)-O (truck trailer) vehicles that are also restricted to 2.55 m for the cargo area.

Why did CEMA put forward a proposal for categorisation (catalogue)?

Due to the different interpretation of Member States on the definitions of R&S vehicles, manufacturers are faced with different national categorisations. This means the same vehicle could be categorised as R in one country and S in another. However, EU countries must accept each other’s EU type approvals.

Often for R vehicles there are other national provisions in relation to the use of the vehicle. For instance , when the trailer is used for haulage, there might be an obligation to hold a truck driver’s license, to undergo periodic inspections, have a tachograph etc. The result is a market demand for e.g. slurry tankers to be categorised as S to avoid this additional provisions. That could push manufacturers to shop around for approvals in the EU. To avoid this possible loophole, CEMA presented a catalogue to give guidance and harmonise the interpretation on R & S under EU Type Approval. This document is not legally binding.

Slurry tankers and other R vehicles with the exemption of ‘trailers’ can still be homologated as S vehicles when they are not transporting load on the road

For instance, if a slurry trailer is not used for transporting load on the road and driving always empty on the road, it can be categorised as S vehicles and it can have its cargo body up to 3 m. CEMA manufacturers agreed on that new configuration. It concerns mainly small slurry tankers with one axle or two axles. Their axle weight fully loaded would be much higher than 10 tonnes but driving on the road empty they remain under the 10 tonnes.


What’s next?

As indicated this is not a binding text but a guidance on a preferred categorisation. CEMA encourages Member States to take over this categorisation or to share their own categorisation and the reasoning. The dialogue has to be started. It is not only a national matter.

CEMA also intends to work on a proposal to receive EU type approval for exceptional vehicles, which could be extra wide, extra heavy (or with higher axle loads)... for T, R and S vehicles, and for self-propelled machines. For these exceptional vehicles, the Member States will keep their right to prohibit these vehicles on all their roads or on certain roads (as is also often the case for national approval). The proposal would however allow all vehicles currently used on the market to receive EU type approval.

It would provide a valuable alternative for the national approval with only one set of state of the art EU technical requirements as embedded in EU type approval but with freedom on national and regional or even communal level to decide on road circulation restrictions.