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European Caravan Federation

ECF

The European Caravan Federation (ECF) is the umbrella organisation representing the national organisations of the European Caravanning Industry.

Lobbying Activity

Meeting with Pascal Arimont (Member of the European Parliament)

23 Jan 2025 · Revision of the Directive on driving licences

Meeting with Pascal Arimont (Member of the European Parliament)

7 Dec 2023 · Revision of the Directive on driving licences

Response to Revision of EU legislation on end-of-life vehicles

4 Dec 2023

The ECF supports the move to a better environmentally friendly industry and is working with its partners on many aspects to improve this including the materials used in the manufacture to enable a reduction in our effect on the environment. However, we feel the inclusion of trailers in the End-of-life vehicle Regulation will have a very minimal benefit with an out of proportion cost to the industry.
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Response to Revision of the Directive on Driving Licences

30 May 2023

The European Caravan Federation (ECF) is the umbrella organisation representing the national organisations of the European RV Industry. Membership of the ECF consists of 16 caravanning federations and numerous national members of the caravanning industry within the EU member states. These members are involved in the production, the sales and the use of touring caravans, motor caravans and the supply of specialist parts and services to the industry. The European Commissions proposal for the revision of the EU Driving Licence Directive has many promising aspects, in particular the proposed update of the driving licence category B to 4.25 t that finally addresses the missing private driving licence above 3.5 t. However, it falls short as only alternatively fuelled vehicles will be allowed to benefit from the extended driving licence category B to 4.25 t. The road to a turnaround in vehicle propulsion is not paved by driving licences alone Holidays with a motor caravan are sustainable, family-friendly and support the political and social desire that more people travel in a climate-friendly, earthbound way. This presupposes that as many people as possible can do this with a modern motor caravan. Today, these are safer and more environmentally friendly than ever. Simple, consumer- and climate friendly regulations are needed to enable people to have a climate- and family-friendly holiday. Environmentally friendly Caravanning should be accessible to all vehicles up to 4.25 t and not only to alternatively fuelled vehicles. The European Caravan Federation welcomes the Commission proposal for a 4th Driving Licence Directive as it will play its major role in improving road safety and the free movement of citizens. But: The B driving licence up to 4.25 t must be accessible to all vehicles. The planned restriction to alternative propulsion systems does not ensure any real progress in the question of how quickly alternatively fuelled vehicles will enter the market. Please find attached the Position of the European Caravan Federation (ECF) on the Commission proposal for a Directive of the European Parliament and the Council on driving licences, amending Directive (EU) 2022/2561 of the European Parliament and of the Council, Regulation (EU) 2018/1724 of the European Parliament and of the Council and repealing Directive 2006/126/EC of the European Parliament and of the Council and Commission Regulation (EU) No 383/20121.
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Meeting with Pascal Arimont (Member of the European Parliament)

13 Mar 2023 · Revision of the Directive on Driving Licences

Response to Revision of the Directive on Driving Licences

21 May 2021

The ECF is the umbrella organisation representing the national organisations of the European Caravanning Industry. Motor caravan tourism should be accessible to all generations and without any unnecessary restrictions. Therefore, all holders of the B driving licence should be given the opportunity to drive vehicles up to 4.25 tons for private use. The current EU driving licence law requires a person driving a motorhome above 3.5 tons for private use to obtain a driving licence for commercial purposes (C1 or C). The C1/C licence is inappropriate, unduly burdensome, complex and time-consuming for private use. Today, the B driving licence entitles a person to drive vehicles with a gross vehicle weight of up to 3.5 tons. At the same time, because of safety and environmental equipment, which is required by EU law, motor caravans are getting heavier and surpass the 3.5 tons limit of the B driving licence. In addition, motor caravans are also becoming more comfortable. Manufacturers have tried to compensate on behalf of motorhome owners by introducing expensive lightweight construction methods and whilst this has slowed this trend, it is proving more difficult to remain within the 3.5 tons limit. Accident statistics do not justify the restriction of 3.5 tons for motor caravan enthusiasts. The number of motor caravans involved in accidents is extremely low across all weight classes. Alternatively fuelled motor caravans are not yet available. Some small and compact electric motor caravans will enter the market soon. However, alternative propulsion systems have the potential of entering the main motor caravan market in greater quantity towards the end of the decade but only if and when new driving licence categories take into consideration already known technical constraints and the additional weight of such systems. The European Caravan Federation ECF therefore calls for a sustainable and future-oriented supplement to European driving licence law. Private use driving licences for over 3.5 tons must not be based on a commercially focused driving licence such as class C1. For private use the driving licence class B is necessary. Proposal: "The weight limit of driving licence category B should be extended to 4.25 tons provided that the use is for private use."
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Response to Development of Euro 7 emission standards for cars, vans, lorries and buses

3 Jun 2020

The European Caravan Federation (ECF) is the umbrella organisation representing the national organisations of the European Caravanning Industry. Membership of the ECF consists of 13 caravanning federations and numerous national members of the caravanning industry within the EU member states. Our members are involved in the production, the sales and the use of touring caravans, motor caravans and the supply of specialist parts and services to the industry. Motor caravans are built in small- and medium-sized quantities. The majority of manufacturers produces less than 500 motor caravans a year. There are many different kinds of motor caravans, many of them build in very small quantities: slim, panel van conversions or semi-integrated vehicles, alcove motor caravans with a big sleeping space above the driver’s cab or luxury A class vehicles. The model range is huge: from small to big, light to heavy etc. Motor caravans are predominantly multistage built vehicles. Their base vehicles are usually vehicles of category N1 or N2 which are designed and constructed primarily for the carriage of goods. Due to the fact that motor caravans are based on category N-vehicles they can’t fulfil all M1 requirements. For multi stage vehicles it is also possible to use the requirements of the base vehicle (2018/858 Annex II Part III Appendix 1). Today’s legislation provides some special processes, for example multi-stage operations. The roadmap states that the effect on multi-stage manufacturers – many of them being SME – would be minor. ECF cautions that multi-stage manufacturers will be affected significantly by a “simplification”. Multi-stage vehicles are produced by modifying base vehicles. The emission approval is done by the base vehicle manufacturer. The converter only uses the emission homologation as supplied by the base vehicle manufacturer and within the limits stated by the base vehicle manufacturer. The "simple" transfer from NEDC to WLTP showed that generating data for multi stage vehicles has been complicated. A “simplification” that does not fully consider the complexity of the multi-stage process will lead to an increased burden. ECF would therefore welcome a statement that the Commission will at least seek for no detrimental impacts on multi-stage manufacturers. However, the very different characteristics of light-duty and heavy-duty vehicles appear to require different testing regimes and measurement systems. The potential for alignment in certain overlapping cases requires further investigation. The latest data indicate that the Euro 6/VI emission legislation is effective. The air quality is continually improving as the market penetration of Euro 6/VI vehicles increases. It is therefore important that the regulatory options proposed by the Commission are assessed not only on the basis of the emission reduction of new vehicles, but also on the basis of the development of air quality. It is important to carry out the impact assessment on the basis of the latest Euro 6/VI regulations. The period mentioned for the impact assessment only covers emission concepts that mainly meet the Euro 6d-temp/Euro VId regulations. The effects of the final Euro 6d standard are not taken into account at all. In view of the current crisis caused by the COVID-19 pandemic and its longer-term effects, a transparent and clearly defined timetable is necessary. Therefore, while we welcome the roadmap presented, an implementation plan, which is unfortunately not available at present, is necessary. In the current situation, it is not possible for industry to stem developments for future regulations without naming concrete goals, measuring methods and schedules. Sufficient lead times need to be foreseen.
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Response to Driving licence legislation ex-post evaluation

9 Sept 2019

Amended B Driving Licence above 3 500 kg necessary EC Type Approval qualifies motor caravans like passenger cars as M1 vehicles. Like passenger cars both kinds of vehicles transport persons (no more eight passengers in addition to the driver) and their luggage. Motor caravans are intended for recreational or holiday usage. In contrary, commercial vehicles of category N are designed primarily for the carriage of goods. The 3rd Driving Licence Directive comprises into category B motor vehicles with a maximum authorised mass not exceeding 3 500 kg and designed and constructed for the carriage of no more than eight passengers in addition to the driver. Driving licence categories C1 and C are primarily intended for the professional transport of goods. Motor caravans with a weight until 3 500 kg can be driven with a B driving licence. Above 3 500 kg driving licence C1 (until 7 500 kg) is necessary, regardless if the vehicle is used for private and or leisure purposes or has the same to similar dimensions. Directive 2012/36/EU acknowledged that “Contrary to category C vehicles, which are dedicated to professional transport of goods, category C1 is heterogeneous and includes a wide range of vehicles, such as vehicles for leisure or personal use, emergency or fire- fighting vehicles, or utility vehicles used for professional purposes but where driving is not the principal activity of the driver” (recital 2). Unfortunately, only the content of the driving licence test for vehicles of category C1 vehicles was adapted to the different characteristics of the vehicles falling under this category. Thus, driving licence categories C1 and C1 97 are almost identical. C1 97 remains as unattractive for private use as C1 has always been. The ECF therefore calls for a sustainable and future-oriented supplement to European driving licence law. Privately used driving licences over 3 500 kg must not be based on the commercially oriented driving licence class C1. For private driving licences an orientation to the driving licence class B is necessary. The weight limit of driving licence category B should therefore be extended based on the following cornerstones:  Intended for private usage only.  Driving licence holder must be over 21 years.  Driving licence must be obtained at least two years before. Justification:  The road safety of motor caravans is excellent . The BASt study confirms a very positive result, with less than 0.3 percent of all accidents involving personal injury being caused by motor caravans. Accidents involving motor caravans are not an urgent road safety problem when considering both the absolute number of accidents and the mileage-related accident risk.  The number of driving licence holders without a suitable driving licence over 3 500 kg for private use is growing.  The driving behaviour of motor caravan drivers has a direct influence on road safety. Motor caravans are usually driven during the day, for private purposes and at "holiday speed". There is no evidence to suggest that motor caravans with a mass of 4 250 kg or 4 500 kg are significantly more difficult to drive than 3 500 kg vehicles.  The dimensions (length, width, height) of motor caravans with 3 500 kg or 4 250 kg are identical. Even motor caravans with a total mass of 4 500 kg are usually identical to those of 3 500 kg.  The masses of motor caravans are constantly increasing. In addition to increasing safety and environmental equipment, customers' ever-increasing demands for comfort are also leading to increasing vehicle masses. Lightweight construction slows down this trend, but does not stop it. Alternatively-fuelled motor caravans will need a total mass of at least 4 500 kg to compensate the additional weight.
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Response to General Safety of Vehicles and Pedestrians

17 Jul 2018

The European Caravan Federation (ECF) is the umbrella organisation representing the national organisations of the European Caravanning Industry. Membership of the ECF consists of 12 caravanning federations and numerous national members of the caravanning industry within the EU member states. These members are involved in the production, the sales and the use of touring caravans, motor caravans and the supply of specialist parts and services to the industry. Motor caravans are manufactured by small and medium sized manufacturers in quantities from 10 to 10.000 annually, generally using base vehicles sourced from major OEM manufacturers of light commercial vehicles. As the safety regulations have been a key factor of improvement of almost all road vehicles, the “caravanning” industry welcomes the project to revise the Vehicle General Safety and the Pedestrian Safety regulations. The ECF notes that the following matters should be carefully considered at all stages when drafting both the primary legislation and the supporting delegated acts: • The adoption technologies should be proportionate with the resulting benefits and costs of adoption. Special consideration should be given to the needs of special purpose vehicles such as motor caravans that are produced in small numbers and contain a large number of special features to allow them to meet their special purpose. Where motor caravans adopt technologically advanced safety systems from the base vehicle the onus for ensuring that the technology is adapted correctly to ensure that it continues to function as intended as part of the completed vehicle should rest with the base vehicle manufacturer. • Consideration should be given to the special requirements of motor caravans where the base vehicle is category N whereas the completed vehicle is category M1SP – special exemptions within Annex II part III appendix 1 of EU 2018/858 (which replaces 2007/46/EC Annex XI appendix 1) may be required for certain technologies for these purposes to ensure that a disproportionate burden is not placed on the motor caravan manufacturer. • Due to the wide variety of layouts, technical features and the low incidence of accidents involving motor caravans the ECF consider that frontal, side, side pole and rear crash testing of completed motor caravans would not offer a proportionate benefit when weighted against the very considerable costs that it would bring to this specialist sector of the industry. The ECF are pleased to see that this appears to have been considered within the initial proposal.
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