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Trailer Industrie Verband e.V.

TIV

Der Verband vertritt die Interessen der Anhängerindustrie und deren Zulieferer gegenüber deutschen und europäischen Repräsentanten aus der Politik, ihren Behörden und Institutionen.

Lobbying Activity

Meeting with Jens Gieseke (Member of the European Parliament, Rapporteur)

30 Jun 2025 · Altfahrzeugverordnung

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

1 Dec 2023

The TIV industrial association - The Trailer Industrie Verband e. V. (TIV), founded in 2015, represents the interests of manufacturers of O1 and O2 trailers (up to 3,500 kg maximum authorized mass, caravans excluded) and their suppliers. The association has its headquarters in Berlin. It currently represents 34 companies from 10 EU and 2 non-EU countries, making it the largest association of its kind within the European Union. - End-of-life vehicles All trailers belonging to Categories O1 and O2 should be exempt from any mandatory end-of-life treatment. The end-of-life vehicle regulation should restrict itself to motor vehicles. After all, only motor vehicles always contain substances and components, mainly in and around the engine, which require careful disposal / recycling while both unbraked (O1) and braked trailers (O2, up to a maximum gross weight of 3.500 kg) do not have an engine. A limited number of trailers, such as vending trailers, may be equipped with machinery such as refrigerators which, when their usefulness has come to an end, must be taken care of properly. However, even under existing rules customers can return such items to the trailer manufacturers who have installed them. In addition, trailers tend to have a long life-span, much longer than cars or other motor-vehicles. Quite often, depending on the care devoted to them, they can last for decades. This is borne out by the fact that whereas occasionally there are abandoned cars along roads, in woods and in parking lots, abandoned trailers are practically unheard of. Up to now, no European trailer market the TIV is aware of has ever seen any demand whatsoever for the disposal and recycling system the draft of the new EU regulation envisions. Consequently, we are convinced that subjecting O1 and O2 trailers to such a system would only make trailers more expensive and create a new bureaucratic monster, something the European Union should take great pains to avoid, particularly in times of multiple crises and declining public confidence in the soundness of Europes economy, the wisdom of the EUs policies and the prospects of the next generation of EU citizens. The trailer industry fully appreciates the importance of protecting our environment for ourselves, our children and our childrens children. However, subjecting O1 and O2 trailers to end-of-life mandatory treatment would do little to further this end. In fact, it would be a mistake. - Berlin, 1st December 2023 The TIV Board of Directors
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Response to Revision of the Directive on Driving Licences

24 May 2023

From the point of view of the TIV, which represents the interests of a large number of O1 and O2 trailer manufacturers and their suppliers, the draft version of the new Directive on Driving Licences still leaves a lot of room for improvement. In the following, we would like to concentrate on Article 9 as it concerns the driving licences most relevant to our members. Subsection (h) stipulates that "two years after a drving licence, granted for category B, was issued for the first time it shall be valid for driving the alternatively fuelled vehicles referred to in Article 2 of Council Directive 96/53/EC [...] with a maximum authorised mass above 3500 kg but not exceeding 4250 kg without a trailer." Having to wait two years is an inconvenience, but one we could live with. However, it does not make any sense to restrict the above-quoted extension of the authorised mass to alternatively fuelled vehicles, which only constitute a small number of the vehicles in use both currently and in the foreseeable future. In addition, excluding the use of trailers is the kiss of death as far as our interests and those of all trailer users are concerned. After all, our objective is to make towing a trailer easier. At the moment, the bigger and heavier the towing vehicle, the smaller the trailer that can be towed, at least under the category B regime. This is both nonsensical and completely unnecessary. In addition, what we suggest is to abolish category BE, effectively incorporating it into category B. Mandatory theoretical training as to how to use a trailer should be made one of the requirements that have to be fulfilled in order to obtain a category B driving licence.
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Response to Revision of the Directive on Driving Licences

19 May 2021

The TIV industrial association The Trailer Industrie Verband e. V. (TIV), founded in 2015, represents the interests of manufacturers of O1 and O2 trailers (up to 3,500 kg maximum authorized mass, caravans excluded) and their suppliers. The association has its headquarters in Berlin. It currently represents 25 companies from 9 EU countries. The deficiencies of the current legal framework The driving licence system, which is in place in the European Union at present, is based on three directives (80/1263/EEC, 91/439/EEC and 2006/126/EC). From our point of view this system calls for urgent reform. What are its deficiencies, as far as O1 and O2 trailers are concerned? For all those who wish to tow an O1, i.e. unbraked trailer, obtaining a category B driving licence is sufficient. If you want to tow an O2, i.e. braked trailer, you also need a B driving licence. However, depending on your towing vehicle and your trailer, it may be necessary for you to get a B96 or BE driving licence, too. Unfortunately, the regulations concerning O2 trailers cause confusion and, quite often, unnecessary cost. When it comes to towing O2 trailers, the category B driving licence imposes a maximum authorized mass (MAM) of 3,500 kg, which applies to the combination of towing vehicle and trailer. This restriction of the MAM to 3,500 kg has a number of negative consequences. First of all, the more the MAM of the car increases, the more the MAM of the trailer goes down. In other words: the bigger and presumably also the more powerful and safer the car, the smaller the trailer it can tow, irrespective of the fact that the fundamental challenges posed by towing an O2 trailer do not depend on its MAM. Second, if someone gets themselves a new car with a higher MAM, they may no longer be able to tow their trailer using their category B driving licence. Consequently, they can either decide not to tow their trailer at all or to pay for a B96 or BE driving licence instead. B96 lifts the MAM of the combination of towing vehicle and trailer up to 4,250 kg, which is undoubtedly better than B but often still not quite enough. That is why B96 seems not to be particularly popular, at least in Germany. BE enables its holders to tow trailers of a maximum authorized mass of up to 3,500 kg. Of course, obtaining a B96 or BE driving licence also means having to spend hundreds of extra Euros—the third potentially unfortunate consequence of the current legal framework. This certainly contributes to the relatively low number of people who wish to get a BE driving licence, at least in Germany. Not surprisingly, the situation as it is has proved to be rather confusing for (potential) trailer users. Their number is bigger than it might seem. In fact, there are many millions of O1 / O2 trailers in the European Union. In Germany alone, on January 1st, 2021, there were 7,867,929 registered trailers (categories O1 through O4, of which O1 and O2 should constitute the vast majority; caravans included). In the Federal Republic, this number has been increasing steadily for many years now. Our reform proposal Category B96 should be merged with category B to give us a new category B. The new B driving licence should allow its holders (1) to tow unbraked trailers of up to 750 kg (maximum authorized mass), as the current category B does, (2) but it should also permit its holders to tow O2 trailers as long as the maximum authorized mass of the combination of towing vehicle and trailer does not exceed 4,250 kg (currently 3,500 kg). At the same time, both theoretical and practical training on how to use a trailer should be made compulsory for all students wishing to obtain a category B driving licence. The reformed category BE would then cater to all those who wish to tow a combination of towing vehicle and trailer in excess of 4,250 kg and up to 7,500 kg. A much more detailed statement can be found in the attached pdf document.
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