6th Report of Market Access Ombudsman Council (March 16, 2000)

3-(4) Changes to the vehicle inspection system for towing vehicles and for towed vehicles

1. Complainant: US Embassy

2. Ministry concerned: Ministry of Transport

3. Background:

(1) In Japan, regulations call for towed vehicles to be inspected hitched to the towing vehicle at the time of new vehicle registration. This is because it is impossible for the towed vehicle to move on roads under its own power, and because when checking whether the towed vehicle meets the safety regulations for road vehicles it is necessary to check conformity with said regulations in the hitched state as well. In addition to towing capability, checking for conformity with safety regulations involves ascertaining the minimum turning radius of the towing and towed vehicles when hitched, operation of vehicle lights, control capabilities, extent of field of vision in the rear-view mirror of the towing vehicle and so on.

(2) The notation column of the vehicle inspection certificate for the towed vehicle notes the name and type of the towing vehicle for which conformity with safety regulations was checked (when the type is not known, the frame number is noted except production run number, manufacturing plant, etc. that each vehicle bears a different number). (Enforcement Regulations for Road Vehicle Act, Article 35-3, No. 15)

(3) At the time of inspection of towed vehicles upon new vehicle registration, or when application for inspection is made for the purpose of adding the type of the towing vehicle to the vehicle inspection certificate, a hitching specification certificate is drawn up for each towing vehicle hitched to the towed vehicle. This certificate contains information on the parking brake of the towing vehicle needed for the towed vehicle. In order to add notations for name and type of multiple towing vehicles on the vehicle inspection certificate of the towed vehicle, it is only necessary to check the said specification certificate when inspecting only the towed vehicle, to determine whether the towing vehicle in question can tow the towed vehicle.

4. Complaint:

Restrictions inherent in the vehicle inspection system make it a de facto impossible for individuals to hitch a camper-trailer (towed vehicle) rented or otherwise borrowed to their own cars in order to go camping. Camper-trailers are relatively expensive and it is also difficult to find places to keep them, so private ownership is difficult, but many consumers would like to use one if they were available for rental, and there appears to be very strong potential demand. Also, if consumers went to areas near campgrounds in their own vehicles and were able to rent camper-trailers there, this would have positive effects where road congestion, the environment and so on are concerned. However, the spread of imported camper-trailers for such uses is impeded.

(1) Carrying out independent inspections of towing vehicles. and mandating labeling concerning towing capacity

Under the current Japanese vehicle inspection system, the towing vehicle is restricted by type (or by frame number, when the type is not known), and inspecting towed vehicles independently, at the time of new vehicle registration, is not accepted. But out of all items, except for towing capacity, which safety regulations specify must be checked in the hitched state, only the vehicle's minimum turning radius depends on the performance of the towing vehicle. Operation of vehicle lights can be checked during new vehicle registration of the towed vehicle by using an available towing vehicle. Scope of the field of vision of the rear-view mirror can be set adequately following instructions in the user's manual or other materials. Accordingly, there is no need to check any of these regulations in the hitched state.
In the United States and Europe, towing vehicles carry labeling regarding towing capacity, and users can select the type of towed vehicle appropriate for the towing capacity of their vehicle.
Thus, the system should be changed to allow independent inspection of towing and towed vehicles at the time of new vehicle registration. Provisions should also be made for mandatory labeling of towing capacity on towing vehicles, to allow consumers to freely select and use towed vehicles.

(2) Simplifying procedures for drawing up hitching specification certificates

The hitching specification certificate required for each towing vehicle must be drawn up by the party making application. However, the figures which must be noted on the certificate require complex calculations that is asked a specialist for the vehicle must be taken in for inspection, and so on. But regarding vehicles manufactured these days, these figures can most likely be calculated from the weight of the towing and towed vehicles.
Accordingly, measures should be taken to make it unnecessary to draw up a hitching specification certificate, by using a conversion chart showing the weights of the towing and towed vehicles to clarify cases in which the towing vehicle has the required weight for towing the towed vehicle, in order to lighten the burden involved in preparing this certificate. When doing so, measures should also be taken to loosen regulations for the parking brake when hitched in the current regulations, since it is excessive for towing the towed vehicle.

5. Results of deliberation:

According to the ministry concerned, since the main type of trailer used in Japan so far has been large semi-trailers used for transporting cargo, insufficient consideration had been given to camper-trailers. Further, in accordance with the safety regulations for road vehicles running performance, brake strength and so on are necessary to ensure safety when the vehicles are hitched, and the hitching specification certificate is needed in order to check safety efficiently. But given that camper-trailers have become much more prevalent in recent years, there is some leeway for simplifying procedures pertaining to meeting s regulations in the hitched state for lightweight camper-trailers, based on their weight, brake system and minimum turning radius and on the presumption that they are safe. This issue will be examined with a view to simplification, by studying the correlation between vehicle performance and vehicle weight.
When new products cannot be handled within the framework of existing systems, it is necessary to review those systems. In such cases, safety must be ensured, but no long periods should be taken to examine whether to introduce in Japan methods which are already in use in Europe and the United States.

Based on the above, the ministry concerned should take the following measures concerning inspection and registration of towing and towed vehicles:

With a view to making it possible to use rented camper-trailers, in order to allow camper-trailers to be towed by vehicles other than those already registered, the ministry should immediately begin examining simplification of procedures when registering camper-trailers, including whether it is possible to introduce an American/ European-style system whereby auto makers label vehicles as to the maximum weight of towed vehicle they have the capacity to tow, and reach a conclusion during 2000 at the latest.

Government decision (March 21, 2000)

3-(4) Changes to the vehicle inspection system for towing and towed vehicles

The following measures regarding changes to the vehicle inspection system for towing and towed vehicles will be taken.

(1) With a view to making it possible to use rented camper-trailers, in order to allow camper-trailers to be towed by vehicles other than those already registered, a study will be initiated immediately to examine simplifying procedures when registering camper-trailers, including whether it is possible to introduce an American/European-style system whereby auto makers label vehicles as to the maximum weight of towed vehicle they have the capacity to tow, and a conclusion will be reached during 2000 at the latest.