COMMISSION OF THE EUROPEAN COMMUNITIES 
C0M<89) 573 final 
Brussels, 22 November 1989 
Proposal for a 
COUNCIL DIRECTIVE 
amending, with a view to fixing certain maximum authorized dimensions 
for road trains, Directive 85/3/EEC on the weights, dimensions and 
certain other technical characteristics of certain road vehicles 
(presented by the Commission) 
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EXPLANATORY MEMORANDUM 
General comments 
Introduction 
On 18 July 1989 the Council adopted Directive 89/461/EEC 
amending Directive 85/3/EEC on weights and dimensions and 
other characteristics of lorries. 
This amendment fixed the load length of an articulated 
vehicle and at the same time increased the total length by 
one meter to 16.5m. 
The main reason for Directive 89/461/EEC was to stop the 
reduction in the space reserved for the driver and the 
coupling device caused by the tendency to make vehicles 
more productive by proposing a maximum usable load length 
within the total length imposed by Directive 85/3. 
By the increase of the total permitted length of the 
articulated vehicle to 16.5m it was possible to take into 
account the load lengths that were possible within the 
15.5m by application of space saving methods as described 
above. 
2. For road trains similar technical developments as for the 
articulated vehicles give rise to additional legislation. 
The basic problem is similar: 
- Within the legally permitted total length of 18 m for 
road trains technical development has, in order to gain 
loading space, led to short cabins and short coupling 
mechanisms between truck and trailer. 
- Disadvantages of ultra short cabins for the comfort and 
safety of drivers were the subject of earlier 
discussions concerning articulated vehicles. 
As regards the use of so called topsleepers the opinions 
as expressed by employers and trade unions in transport 
differ widely. 
The employers view is that top sleeper vehicles 
constitute a modest part only of total heavy vehicles 
(potentially 9 %). A large majority of drivers jobs will 
not necessitate the use of top sleepers. Also, 
individual preferences of drivers can be respected as in 
the total driver population there are sufficient drivers 
' able and willing to drive top sleeper vehicles. 
The trade unions have serious objections as regards the 
use of topsleepers because of accessibility, 
ventilation, safety in case of accidents or fire and 
feelings of claustrophobia by certain drivers. 
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The technology of flexible coupling systems has in some 
cases led to a "theoretical" distance of 8 to 15cm 
between truck and trailer. This distance can be 
increased sometimes from the cabin, if necessary, by 
extending the length of the coupling itself or by a 
system that moves the container on the trailer backwards 
by means of a sledge. 
It is obvious that a distance of 15cm can only be 
maintained on a flat and straight route so the total 
length of the combination will in practice often be 
considerably more than 18m. 
The extreme result of using short cabins and coupling 
devices is a vehicle with a total length available for 
loading of 16.40m which still theoretically meets the 
overall length of 18m. 
It is clear that such a vehicle has economic advantages 
and that this concept will have a quick and large 
proliferation if no additional legislation is adopted. 
Also companies and vehicle manufacturers that have 
serious objections as regards technical and social 
aspects of such vehicles will be forced to use them and 
to produce them in order to stay competitive. 
The aim of this Proposal for a Directive is to 
complement the Community legislation in order to stop 
this development. 
2. Legal aspects 
Directive 85/3/EEC allows the free circulation in 
international traffic of road trains with a maximum length 
of 18m. 
On the basis of the Directive 85/3 as in force now, no 
ultra short cabins with topsleepers can be forbidden. 
Member States that do so in their domestic legislation 
disadvantage their own operators in comparison with 
foreign operators that enter their territory. 
As regards the flexible coupling mechanism the legal 
position is less clear. A road train that is 18m long if 
stationary but that exceeds this length regularly when it 
moves does not reflect the spirit of Directive 85/3 that 
lays down length limitations not for vehicles on the 
parking place but for vehicles in traffic. 
The proposal for an amendment to Directive 85/3 has to 
take into account the legal position of vehicles that are 
already on the road and that were built under the original 
legal protection of 85/3. 
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However if by introducing new legislation from a certain 
date new concepts are less competitive than the "old" ones 
then a situation will be established which is undesirable 
and difficult to enforce. 
3. Technical aspects 
The total length of a road train is the sum of 
A) cabin length 
B) coupling distance between truck and trailer 
C) total length available for loading 
Point A 
On going discussions between the social partners will 
establish minimum standards for.the drivers' cabin with 
or without a bed. 
In Directive 89/461/EEC a method is adopted of ensuring 
enough space for a comfortable cabin within the total 
length without fixing the details. 
Reasons for this method are as follows: 
. Fixing a minimum cabin dimension would lead to the 
manufacture of only the minimum requirements; economic 
pressures would ensure this. Manufacturers that wanted 
to use extra cabin space for comfort or safety could 
only do so by reducing load length. 
. Assuming that certain accomodations for sleeping 
(small beds, top sleeper) are not acceptable, it will 
still be very difficult to control the use of them. 
Nobody can be prohibited from constructing a small space 
on the roof of a daycab. It will be impossible to 
control if this space is used for resting or sleeping; 
it is even impossible to control if a driver sleeps on 
his seat 1 
A much better approach is to disencourage this practices 
by taking away the incentive of creating more loading 
space by application of short cabins. 
Once these standards are agreed they will be compatible 
with legislation in Directive 89/461/EEC which is aimed 
at ensuring that enough room is reserved for the 
driver's cab. 
There are no arguments why the cabin of a road train 
should differ from the cabin of an articulated vehicle. 
Manufacturers will like to apply the same models and 
drivers work under similar conditions. 
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The space reserved for the cabin in Directive 89/461/EEC 
can be calculated as follows : 
total available length: 16.50 m 
minus distance from fifth wheel to the 
rear of the semi-trailer: - 12.00 m 
minus forward clearance of semi-trailer: - 2.04 m 
minus free space between tractor and 
semi-trailer (according to 
ISO standard 1726): - 0.20 m 
So available space for the cabin from 
front to back wall: 2.26 m 
Applying the same cabins for road trains means that 2.26 m 
should be available. 
However, for the road train an additional 0.10 m or so 
should be added for cab clearance, driver safety, 
roofmounted vertical exhaust and necessary space for 
picking up the swap body. This brings the total necessary 
length to 2.35 m. 
Point B 
The length of the coupling device depends on the 
technology that is applied. For couplings of road trains 
no ISO standards like for the articulated vehicles are 
available. 
The normal coupling device requires a coupling distance of 
around 1.5 m. By short coupling devices this distance can 
be reduced to 1 m and if a centre axle trailer is used to 
0.7 m. 
The use of extendable couplings or other technology that 
lengthen the total length of the combination when 
driving should not be taken into account in this 
calculation. These mechanisms have not yet been proven to 
be reliable under all circumstances and are very costly. 
In so far as they are invented only to bypass the 
international agreed length limits their use should be 
discouraged by taking away the incentives in that respect. 
Point C 
The total load length is the third element that determines 
the overall length. 
As argued above a minimum space of 2.35 m should be 
reserved for the cabin including the clearance and a space 
of 0.70 m is necessary for the shortest non extendable 
coupling mechanism. 
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Applying the same method as used in Directive 89/461/EEC 
for the articulated vehicle means that overall length and 
loading length must be fixed in such a way that enough 
space for cabin and coupling is guaranteed. 
This means that the overall length of the road train 
should be fixed at 2.35 ro longer than the load length 
including the coupling distance between truck and trailer 
and moreover that the overall length should be fixed at 
3.05 m longer than the load length. 
In Directive 89/461/EEC for articulated vehicles the 
maximum load length that was feasable under the old limit 
could be taken into account by increasing the overall 
length with 1 m from 15.5 ro to 16.5 m. 
At present some road trains, though with extendable 
couplings, operate with a load length of 
2 x 8.22 m <* 16.45 ro 
Taking this load length into account would require a total 
length of 16.45 + 3.05 = 19.50 m. 
This would mean an increase of almost 9 % of the length of 
the longest combination on the road which is politically 
unacceptable for roost governments of the Community. 
Starting from the other side, the longest acceptable 
combination for the majority of the Member States seems to 
be 18.35 m bearing in mind that most Member States allow 
at present a two percent tolerance on the 18 m limit. 
Calculating backwards this means that the maximum 
available load length for a road train should be fixed on 
18.35 - 3.05 = 15.30 ro. Any load length above this number 
would implicate an increase of the overall length above 
the 18.35 m. 
An additional argument for this length is the great 
problem that could be provoked for the transit traffic 
through Austria and Switzerland if a longer combination 
was permitted in the Community. 
The important reference in the field of load length are 
the standard lengths of swap bodies that at present are 
used. 
In the CEN working group the following lengths for 
general purpose swap bodies class C were approved: 
7150, 7420 and 7820mm. 
The first length 7150mro is the roost frequently used at 
present. The 7420roro length was especially promoted by 
Sweden as a good logistic solution. 
Standardization of the swap bodies of 8220mm which are 
also on the road now, has not yet been considered by CEN. 
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A maximum load length of 15.30 ro will allow transport of 
the following combinations of standard swap bodies and 
containers: 
2 x 6.058 ro (20 ft container) 
2 x 7.15 ro 
2 x 7.42 ro 
1 x 6.058 ro + 1 x 7.82 m 
1 x 7.15 ro + 1 x 7.82 ro 
1 x 6.058 ro + 1 x 8.22 ro 
1 x 7.42 ro + 1 x 7.82 m 
Transport of 2 x 7.82 ro swap bodies would only be 
possible if the total length was increased to 
15.65 + 3.05 - 18.70 ro. 
For the transport of 2 swap bodies of 8.22 ro the above 
calculated increase to 19.50 ro would be necessary. 
Both options are not acceptable for reasons of road safety 
and public acceptance. Therefore transitional measures 
should be taken for these swap bodies which are now on the 
road. 
4. Conclusion 
The following options are possible as regards additional 
Community legislation: 
a) the "zero" option: no action or no agreement 
Result: A quick proliferation of ultra short cabins and 
complex flexible coupling systems for international 
transport. 
b) Fixation of loading length and the overall length of 
road trains. 
This additional legislation for lengths of road trains 
should 
• take away incentives for short cabins, 
. be considered in relation with legislation for artics, 
. make clear that extendable couplings do not give 
advantages for the load length, 
• take into consideration the standard swap bodies 
. take into consideration the current situation. 
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Contents of the proposal 
5. Article 1 of Annex I of Directive 85/3/EEC will therefore 
be amended on the following points: 
- The maximum authorized length of a road train will be 
increased from 18.00 ro to 18.35 ro. 
- The total load length of the combination of truck and 
trailer will be fixed by prescribing a maximum length of 
15.30 m for the sum of the load lengths of truck and 
trailer. 
- The sum of the total load length of a combination of 
truck and trailer and the distance between truck and 
trailer will be fixed on 16.00 m. 
A new Article 4b is inserted in Directive 85/3/EEC which 
will allow the use of existing road trains that do not 
comply with the provisions on total load length on 
condition that these vehicles do not exceed the "old" 
maximum authorized length of 18 ro. 
In order to avoid a permanent advantage of old 
combinations that were built with more load length than 
allowed in the proposal this exemption is limited until 
1 January 1995. 
I 
Proposal for a 
COUNCIL DIRECTIVE 
amending, with a view to fixing certain maximum authorized dimensions 
for road trains, Directive 85/3/EEC on the weights, dimensions and 
certain other technical characteristics of certain road vehicles 
THE COUNCIL OF THE EUROPEAN COMMUNITIES, 
Having regard to the Treaty establishing the European 
Economic Community, and in particular Article 75 thereof, 
Having regard to the proposal from the Commission (1), 
Having regard to the opinion of the European Parliament (2), 
Having regard to the opinion of the Economic and Social 
Committee (3), 
Whereas, in order to make combined vehicles more productive, 
manufacturers are proposing a maximum usable volume within 
the constraints imposed by Council Directive 85/3/EEC (4), as last 
amended by Directive 89/461/EEC (5); 
Whereas this increase in the usable volume involves a 
reduction in the space reserved for the driver and in the 
space between the truck and the trailer by means of special 
coupling devices; 
Whereas there is a consequent deterioration in the comfort 
and safety of the driver's working area; 
Whereas the current standards should be improved so as to 
lead to a better balance between the rational and economic 
use of commercial road vehicles and the requirements of road 
safety while ensuring that drivers have enough room; 
(1) OJ No . £ 
(2) OJ No % 
. ft-
(3) OJ No J 
(4) OJ No L 2, 3.1.1985, p. 14. ^ 
(5) OJ No L 226, 3.8.1989, p. 7. 
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Whereas the incentives for increasing loading space by the 
use of short cabins with top mounted sleepers should be 
removed; 
Whereas the new fixed dimensions will enable the use of a 
drivers' cabin with a sleeping place behind the drivers'seat 
of which the effective width is about 80 cm, 
HAS ADOPTED THIS DIRECTIVE: 
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Article 1 
Directive 85/3/EEC is hereby amended as follows: 
1) The following Article is inserted: 
"Article 4b 
Road trains put into circulation before 1 July 1990 which 
do not comply with the new specifications contained in 
points 1.7 and 1.8 of Annex I shall until 1 January 1995 
be deemed to comply with such specifications for the 
purposes of Article 3(1) if they do not exceed the total 
length of 18,00 m.M 
2) Point 1.1 of Annex I is replaced by the following: 
"1.1. Maximum length 
- motor vehicle 12,00 ro 
- trailer 12,00 ro 
- articulated vehicle 16,50 m 
- road train 18,35 m 
- articulated bus 18,00 ro". 
3) The following points are inserted in Annex I: 
1.7. Maximum distance measured parallel to the 
longitudinal axis of the road train from the foremost 
point of the loading area behind the cabin to the 
rearmost point of the trailer of the combination» 
minus the distance between the rear of the truck and 
the front of the trailer 15,30 m. 
1.8. Maximum distance measured parallel to the 
longitudinal axis of the road train from the foremost 
point of the loading area behind the cabin to the 
rearmost point of the trailer of the combination 
16,00 ro. 
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Article 2 
Member States shall take the measures necessary to comply 
with this Directive not later than 1 January 1991. They shall 
forthwith inform the Commission thereof. 
The provisions adopted pursuant to the first paragraph shall 
make express reference to this Directive. 
Member States shall communicate to the Commission the 
provisions of national law which they adopt in the field 
governed by this Directive. 
Article 3 
This Directive is addressed to the Member States. 
Done at . • For the Council 
The President 
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COMPETITIVENESS AND EMPLOYMENT IMPACT STATEMENT 
I• What is the main reason for introducing the measure ? 
This proposal concerns the fixation of a maximum autho­
rized load length of road trains and an increase of the 
maximum authorized overall length from 18,00 to 18,35 m. 
This total package is introduced in order to guarantee 
sufficient space for the cabin and the coupling device 
within the total length of the road train. 
This proposal is the logical follow-up of a similar 
Directive 89/461/EEC by which the load length of semi 
trailers was fixed in order to guarantee enough length for 
a comfortable drivers' cabin and a reliable coupling 
mechanism for articulated vehicles. 
However, it will not be possible to increase the admitted 
overall length of road trains in such a way that all 
existing load lengthes will be covered by the new 
legislation. 
Therefore an article has been incorporated allowing all 
existing road trains that do not meet the new restrictions 
on load length to be used in international traffic until 1 
January 1995. 
II» Features of the business in question 
All enterprises which use these vehicles for transfrontier 
operations and vehicle manufacturers. 
III. What obligations does this measure improve directly on 
businesses? 
Road trains used in international traffic shall be 
complied with the provisions of this proposal. 
IV. What indirect obligations are national, regional or local 
authorities likely to impose on business 7 
Implementation of the obligations as described under III. 
V. Are there any special provisions in respect of SME's ? 
None. 
VI. What is the likely effect on : 
a) The competitiveness £f_business 
The internal competitiveness of enterprises using road 
trains will be equilized by prescribing load lengths. 
b) Employment 
Positive r* 
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VII. Have the relevant representative organisations been 
consulted ? 
The representative organisations of vehicle 
manufacturers, operators and unions have been 
consulted. Their opinions are as follows : 
Vehicle manufacturers and operators want a greater 
overall length and the use of short cabins with top-
sleepers in limited cases in order to accomodate load 
lengths that are used now by the application of ultra 
short cabins and flexible couplings. 
The Unions are against the use of top sleepers. 
JH 
ISSN 0254-1475 
COM(89) 573 final 
DOCUMENTS 
EN 07 oi 
Catalogue number : CB-CO-89-558-EN-C 
ISBN 92-77-55339-1 
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