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Compliance summary: small trailers – how compliant are yours?

Small trailers play a major part in the movement of goods and equipment throughout the UK.

Small trailers play a major part in the movement of goods and equipment throughout the UK. They are used by utility companies, tool hire firms, local authorities and many tradesmen such as builders and landscape gardeners. Usually towed behind a 3.5 tonne light commercial vehicle or 4x4 they carry anything from ride on mowers to mini diggers or general sundries such as building supplies. Unfortunately, they are sometimes neglected where maintenance is concerned and generally taken for granted.

Due to their Maximum Authorised Mass (MAM) and the design of the braking system usually being an overrun braking system, it means they are exempt from annual MOT and plating and testing (trailers with no other brakes than a parking brake and brakes that come automatically into operation on the over-run trailer). Although they may be exempt from an annual test, they must still be kept in a roadworthy condition when used on the public highway.


Firstly, check the trailer manufacturer’s plate, which will display the MAM of the trailer and relevant axle weights, none of which should be exceeded. Ensure your drivers are aware of these. If found to be overweight when stopped by roadside enforcement, this can have serious consequences for the driver and operator.

Where operators are governed by an operator licence, but also have light vehicles including small trailers in their fleet which may be exempt/out of scope of operator licence, defects found at roadside checks on such vehicle combinations can still have a detrimental effect on a company’s operator licence.

In the introduction to DVSA’s Guide to maintaining roadworthiness it states:

The Driver and Vehicle Standards Agency (DVSA) has produced this guide to

explain the responsibilities and systems involved in maintaining vehicles in a

roadworthy condition, regardless of operating conditions, fleet size or vehicle

type. The procedures and systems explained in this guide are useful for operators,

drivers and all those who are responsible for operating, maintaining or providing

commercial goods and passenger carrying vehicles. The general principles

apply equally to light goods and passenger vehicles below the operator licensing

thresholds and for vehicles that are otherwise exempt.

A previous trial carried out by roadside enforcement highlighted a concern over the roadworthiness of small trailers.

The trial consisted of stopping such trailers and examining them at roadside, where they discovered defects relating to the following:

  • brakes
  • tyres
  • lights
  • breakaway cables


The defects found produced a prohibition rate of 40%.

Regulation 100 – The Road Vehicles (Construction and Use) Regulations 1986 states the following:

Maintenance and use of vehicle so as not to be a danger, etc

100. (1) A motor vehicle, every trailer drawn thereby and all parts and accessories of such vehicle and trailer shall at all times be in such condition, and the number of passengers carried by such vehicle or trailer, the manner in which any passengers are carried in or on such vehicle or trailer, and the weight, distribution, packing and adjustment of the load of such vehicle or trailer shall at all times be such, that no danger is caused or is likely to be caused to any person in or on the vehicle or trailer or on a road. Provided that the provisions of this regulation with regard to the number of passengers carried shall not apply to a vehicle to which the Public Service Vehicles (Carrying Capacity) Regulations 1984apply.

(2) The load carried by a motor vehicle or trailer shall at all times be so secured, if necessary, by physical restraint other than its own weight, and be in such a position, that neither danger nor nuisance is likely to be caused to any person or property by reason of the load or any part thereof falling or being blown from the vehicle or by reason of any other movement of the load or any part thereof in relation to the vehicle.

(3) No motor vehicle or trailer shall be used for any purpose for which it is so unsuitable as to cause or be likely to cause danger or nuisance to any person in or on the vehicle or trailer or on a road.


Ensure drivers carryout a daily walkaround check on their vehicle and trailer which is documented and retained accordingly in paper format or electronically. Where these types of trailer fall in scope of the operator licence, maintenance documentation will need to be retained for the minimum of 15 months. This will include any positive defect reports. Safety inspection intervals will also have to comply with stated frequency on your operator licence.

Give drivers adequate training on the combination, which apart from the standard items such as lights, tyres and bodywork, should also include the correct coupling and uncoupling procedures to follow. The coupling is usually through a 50mm tow ball or pin assembly.

Make drivers aware of extra items to check, such as the breakaway cable/chain, the jockey wheel and any wiring that connects the trailer to the towing vehicle. The correct stowing of any electrical cable/connector is important, as these can be easily damaged if not stowed correctly. Damage to such connectors (usually 13-PIN but can be a 7-PIN connector), will ultimately affect the operation of the lights, rendering the trailer unroadworthy.

Depending on the type of load the trailer is carrying, there must be the correct load securing equipment available and in good condition. This could include ratchet straps, ropes, chains, or some form of netting.

Load distribution should also be considered, so any manufacturers’ MAMs including axle weights are not exceeded. Where a small trailer is concerned this would also include the nose weight. How the trailer is loaded can also affect the towing vehicles rear axle weight which can cause an overload situation to the towing vehicle.

The operator should ensure a maintenance regime is put in place for regular safety inspections/servicing which they can demonstrate should the need arise. Manufacturers’ recommended guidance should be followed. Many operators incorporate these into their maintenance planner so they are inspected at the same interval as their light commercial vehicles.


It pays to look after any small trailers in your fleet, in doing so they will remain an asset and trusty workhorse for your business. If you do not, they can cause the same headaches as any other vehicle in your fleet.


Published On: 20/01/2022 16:00:03


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