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
Date: 1989-11-22
Institutions: European Commission
Subjects: road transport, standard, vehicle, weight and size

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) 

<£*/-> >7 J ^? 

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: 
minus distance  from  fifth wheel  to the 
rear of the semi-trailer: 
minus  forward  clearance of semi-trailer: 
minus  free space between tractor and 
semi-trailer  (according  to 
ISO standard  1726): 

So available  space for the cabin from 
front to back wall: 

16.50 m 

- 12.00 m 
-  2.04 m 

-  0.20 m 

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 . 0 58  ro  +  1  x  7 . 82  m 
1  x  7 . 15  ro  +  1  x  7 . 82  ro 
1  x  6 . 0 58  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 

(3) OJ No 
(4) OJ No  L 
(5) OJ  No  L 226,  3.8.1989,  p. 

2,  3.1.1985,  p.  14. 
7. 

.  £ 
% 
. ft-
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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: 

JO 

-  3 

-

A r t i c le  1 

Directive  85/3/EEC  is  hereby  amended  as  follows: 

1)  The  following  A r t i c le  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 

- trailer 
-  articulated vehicle 
-  road train 
-  articulated bus 

12,00 ro 

12,00 ro 
16,50 m 
18,35 m 
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 
15,30 m. 
the front of the trailer 

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. 

^y W 

- 4 -

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 

J 

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 

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-  2 -

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 

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07  oi 

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ISBN 92-77-55339-1 

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