At the request of the company AZ-Automobile GmbH in 65520 Bad Camberg, as a “certified installation company” for ALUGAS pressurised gas containers, the GAGT e.V. would like to deal with so-called “fake news” in connection with the activities of individual employees of the “monitoring organisations” during the acceptance of vehicles on the occasion of a main inspection according to § 29 StVZO, including §41a StVZO, for a motor caravan/caravan. Of course, this also includes the so-called gas system tests according to DVGW G 607 and their assessments within the scope of a main inspection (HU). Here, because of the topicality in the media and so-called “trade journals”. Especially and in particular as an example, with a product of the company ALUGAS from Bad Sobernheim, with its pressurised gas container “Travel Mate” and its use in motor caravans/caravans.
There is some “fake news” circulating in the public about these “Travel Mate” pressurised gas tanks, which is being spread with manipulative intent. We will take a closer look at this “fake news” here today with reference to the actual circumstances and the current legislation in Europe. As this legislation continues to make headlines with manipulative intent, to the detriment of a manufacturer (ALUGAS), we will now confront you with the actual facts and make a correction.
“Fake News” No. 1
ALUGAS “Travel Mate” pressurised gas tanks, after being set up and fixed in a designated “gas box”, specified by the vehicle manufacturer of a motor caravan/caravan, must subsequently be approved by a “monitoring organisation” (TÜV/DEKRA/KÜS…etc.), in accordance with § 21 in conjunction with §19 Para. 2 StVZO and then entered in the registration certificate Part I, by the road traffic authorities.
Correct: ALUGAS pressurised gas containers, after their sale to the customer, with handing over of the installation and operating instructions (original of the manufacturer) and the type approval according to CE – 0036 according to ODV, comply with the ODV regulation, as well as the product liability law (Germany) and the product safety law (Germany), following and referring to the directive 85/374/EWG (liability for defective products). It should also be noted that these pressurised gas containers are thus approved for sale in Europe in accordance with all directives and regulations.
However, it is also true that pressurised gas tanks for LPG (propane/butane), for operating heaters, refrigerators, etc. in a motor caravan/caravan and here subsequently, e.g. with an attachment to the underbody of the vehicle (chassis) or in an attachment point not expressly designated (by the manufacturer) and provided with an ABE, must of course be approved by a “monitoring organisation” after submission of all the necessary documents and must then be registered with the road traffic authorities in the registration certificate Part I. This must, however, be done beforehand, the installation of the LPG tank must be approved by the manufacturer. However, the company installing the tank must first provide the “monitoring organisation” with all the necessary documents from the tank manufacturer, in conjunction with installation instructions and the associated add-on parts, as well as a type approval for the vehicle in accordance with the regulations, e.g. a UN ECE R… regulation, stating the installation location on the vehicle, from the vehicle manufacturer (OEM) with an ABE. This is the only way that an acceptance test in accordance with § 21 StVZO can be checked and accepted by a PI or aaSoP of a “monitoring organisation”. Only with these papers from the “monitoring organisation” may a road traffic authority enter this conversion in the registration certificate Part I. Without these papers from the tank manufacturer and the OEM, the operating permit is invalidated after the vehicle has been converted. The vehicle may no longer participate in public road traffic. As far as GAGT e.V. is aware, this applies to many motor caravans/caravans that have already been converted.
“Fake News” No. 2
After the installation and non-registration of ALUGAS “Travel Mate” pressurised gas tanks, the insurance cover for the motor caravan/caravan expires completely with regard to “third party liability insurance” as well as “fully comprehensive insurance” and “partial comprehensive insurance”.
Correct: The German Insurance Association (Gesamtverband der Deutschen Versicherungswirtschaft e.V.) in Berlin was presented with statements on the lapse of insurance cover in all details, presenting the ALUGAS pressure container “Travel Mate”, both verbally and in writing, as well as relevant pictures. The result is unambiguous: When using these pressurised gas containers and the certified and handed out “conformity” of these by the ALUGAS company, also using the “operating and installation instructions”, for the type-approved “gas box” (receptacle) according to the specifications of the vehicle manufacturer, there are no concerns by an insurer according to the general terms and conditions. In this context, the GAGT e.V. has agreed with the GDV e.V. to continue to maintain contact in insurance matters, as the future will still hold some questions about future technologies and their coverage by insurance. For these companies, too, the customer is the focus and must be and be informed about innovations in a timely manner.
“Fake News No. 3
ALUGAS pressurised gas containers “Travel Mate” must be certified according to UN ECE Regulation 67/01 and in this respect must also be attached to the vehicle in such a way that they can withstand 20 g in the direction of travel and 8 g in the horizontal direction in the event of an impact with an obstacle.
Correct: On 1 November 2003, the Federal Republic of Germany deleted from national legislation without replacement the standard DIN EN 12979 (German version) that had been valid until then, entitled: Systems for LPG-fuelled (LPG) vehicles – installation regulations. However, in order to avoid a lawless vacuum, the international legislation of the “United Nations”, with the regulation UN ECE R 115, has now been introduced and declared generally binding for Germany. This regulation now only had to be transferred into a legally binding regulation in Germany/Europe. This was done on 16 March 2006 with the introduction of § 41a into the StVZO and in connection with the amendment to the 42nd VO-StVR (BGBl S 543, VkBl S 418 published and could now come into force. Within the framework of these now valid application specifications, the so-called GAP (authorisation of gas system tests) and the GSP (gas system installation test) with the necessary tests to be carried out by authorised persons and companies etc. have now been specified in a binding manner, taking into account § 41a of the StVZO in conjunction with Annex XVII and XVIIa. It should be part of the general knowledge, especially for “monitoring organisations”, master vehicle workshops and road traffic authorities, to know the exact wording of § 41a of the StVZO. After all, it is part of the training to become a PI and/or aaSoP of “monitoring organisations” and a component of the Motor Vehicle Expert Act (KfSachvG) and the Ordinance on the Implementation of the KfSachvG (KfsachvV), as well as in other prescribed training courses, which are laid down by the legislator in a binding manner. All this and more is laid down in the StVZO and is part of the daily application in/at GAGT e.V. It should now be added that the retrofit gas system regulation UN ECE R 115 may only be used in motor vehicles for propulsion purposes if this retrofit gas system is installed and used purely for the operation of an internal combustion engine. Gas system tests in relation to the use DVGW G 607 or ECE 122
The regulation UN ECE R 115, however, only describes the installation of an aftermarket gas system, with all its obligatory tests required by the legislator (type approval authority), in Germany e.g. the Kraftfahrt-Bundesamt (Federal Motor Transport Authority), upon presentation of a valid officially issued type approval by the applicant/manufacturer of the aftermarket gas system. However, UN ECE 115 now also includes UN ECE R 83 (Uniform provisions concerning the approval of vehicles with regard to the emission of pollutants from the engine in accordance with the fuel requirements of the engine), which deals with pollutants from internal combustion engines. Again, as a reminder…, we are talking about the installation of aftermarket gas systems in motor vehicles with internal combustion engines and not gas system installations of/in motor caravans/caravans. Only Regulation (EU) 2016/426 on appliances burning gaseous fuels and repealing Directive 2009/162/EC is responsible for the interior fitting of components with LPG appliances (refrigerator-gas stove-heater). If someone still has the idea of wanting to cite a regulation according to UN ECE R 122, it should be pointed out that this regulation only stands for “Uniform Technical Prescriptions concerning the type-approval of vehicles of categories M, N and O with regard to their heating systems” and does not stand for their tests according to DVGW G 607. It should also be said here that Struma heating systems are installed “maintenance-free” in motor caravans/caravans and switch off independently if a fault occurs and can only be reused after a repair by the company TRUMA. It is not possible to have these heaters from TRUMA inspected by an “expert” in accordance with DVGW G 607. According to TRUMA, this is only reserved for TRUMA.
The regulation UN ECE R 115, however, also defines the content of the regulation UN ECE R 67, as part of a component in connection with the requirements for LPG fuels (DIN EN 589) according to the 10th BImSchV from 2019 of a retrofit gas system. This UN ECE R 67 is not an INSTRUCTION for retrofit gas systems, not even for motor caravans/caravans, as is often wrongly quoted in public, but quote: I Approval of the special equipment of vehicles of classes M and N in whose propulsion system liquefied gases are used. So this regulation UN ECE R 67, only deals with the use of type-approved COMPONENTS, which in UN ECE R 115 are bindingly provided with all the type-approvals in paper form per component, may only be used and installed.
So once again for the record: UN ECE R 67 is part of UN ECE R 115, as is UN ECE 83, all of which are laid down in the Road Traffic Licensing Regulations (StVZO) and here in § 41a. StVZO and its annexes using the individual UN ECE regulations.
For motor caravans/caravans of class MI and class O, this regulation UN ECE R 67 in connection with gas system installations explicitly does not apply. Gas systems in motor caravans/caravans must be type-approved by the manufacturer of these vehicles before they can be placed on the market, also for a so-called body on a chassis (living area). In the past, this type approval was granted to the manufacturer in application of Directive 2007/46/EC and with reference to DIN EN or ISO standards. New vehicles are now subject to type approval from 01 September 2020 under Regulation 2018/858/EU, replacing Directive 2007/46/EC. Both also mean that if modifications are made to a vehicle by the manufacturer or the owner that do not comply with a type approval, the granted type approval expires without any ifs and buts. But also, the manufacturer now bears the responsibility, after a type approval has been granted by the legislator, under the Product Liability Act and the Product Safety Act, after a sale to a customer, even beyond the period of a guarantee or warranty, in the event of damage which is not the responsibility of the consumer but which may call into question the operational safety. See also the millions of recalls by vehicle manufacturers in recent times. The motor caravan industry, too, is currently confronted with exhaust gas problems in its vehicles.
Let us now turn to the standards DIN EN 12979 and DIN EN 1949+A1 (2013-02), which everyone likes to talk about and which are used for everything. DIN EN 12979 has never existed for interior fittings with gas components in motor caravans/caravans (there is no legislation on this at all). In the past, it was simply borrowed from passenger cars for these vehicles. However, it has also simply expired for passenger cars since November 2003, even if nobody seems to want to accept this. Regarding DIN EN 1949+A1, the following remains to be reported after a letter from the GAGT e.V., on request to the DIN German Institute for Standardisation e.V. TBT information centre (on behalf of the Federal Ministry for Economic Affairs and Energy).
Here is the wording of the TBT information centre to the GAGT e.V.:
Dear Mr Ziegler, thank you for your enquiry, which has been forwarded to the TBT Enquiry Unit at DIN. The TBT Enquiry Unit is responsible for researching technical legislation, standards and information relevant to the WTO Trade Agreement.
In my research, I was unable to identify any references of any legislation to DIN EN 1949 (2013-05). Nor to the identical European standard EN 1949+A1 (2013-02) …. End of the communication.
This communication confirms once again that DIN EN standards are almost compulsively misused as a starting point for illegal applications with regard to installed gas systems in motor caravans/caravans, in order to carry out tests on these vehicles, such as the DVGW G 607 application, of course, for a fee. This without a legal basis and protection by a directive or regulation, a DIN EN standardisation whichever, must be laid down in the EU or Germany in order to become effective. This statement is already being confirmed by some of the higher state authorities and their responsible transport ministries. You just won’t find any legislation that could fit anything in connection with “tests” for motor caravans/caravans.
Here is another quote:
Mr. Ziegler, unfortunately we have not found any legislation that would justify gas system tests according to DVGW G 607. And thus these are also not permissible. Should someone as a “monitoring organisation” now refer to § 29 StVZO with a defect tree, they will now act according to the motto…if they do not have a gas system test according to DVGW G 607, they will not get a sticker for an otherwise passed main inspection according to §29 StVZO without defects. In the opinion of the GAGT e.V., this behaviour is simply coercion according to the penal code and despite resistance from customers, who are now under massive pressure, an order is placed, otherwise the customer would have to drive home without having achieved anything. The defect tree listed in § 29 of the German Road Traffic Licensing Regulations (StVZO), with a description of a defect and its assessment on the test report, refers exclusively to a gas system test (GAP) for vehicles with retrofit gas systems, according to the UN ECE R 115 regulation and only binding in connection with regulation 115. Here again, a “monitoring organisation” simply borrows a “gas test” (GAP) for lawless tests on motor caravans/caravans, but no one notices…but GAGT e.V.!!!
In addition, a question must be asked here, why do “caravans” not have to prove gas tests according to DVGW G 607 during main inspections according to § 29 StVZO? They also have LPG gas equipment on board, don’t they? The answer to this question is quite simple: In the opinion of the GAGT e.V., it is not the legislator who makes the laws, no, it is the “monitoring organisation” which does this under the eyes of the legislator and the control bodies themselves…Great!
This shows once again that control by the legislator does not actually take place and that “monitoring organisations” can freely help themselves to the customer’s purse, just like that. There seems to be not only a mask scandal, a toll scandal, a subsidy scandal and the outflow of Corona aid to Islamist extremists, there is also an “audit scandal”, under the supervision of the legislator and has now also established itself, only this is also geared to a long time in the future and more lucrative in the total sum over the next few years than anything else.
Who actually earns many gigantic millions from these demonstrable violations of the law and the sums of money involved, especially since the legislator has known about these violations of the law for more than fifteen years and nothing has been done. This question should be clarified as soon as possible, the GAGT e.V. has also received letters from owners of motor caravans, which already give an idea of the partly harassing behaviour of “monitoring organisations” during main inspections according to § 29 of the German Road Traffic Licensing Regulations (StVZO) and gas system inspections according to DVGW G 607. I see, the suspension of the gas system test according to DVGW G 607 until 01.01.2023 is due to the efforts of the GAGT e.V., because we were once again able to prove that measuring devices did not have an approval and therefore could not be used. Nothing has changed in this respect to date. Of course, there is now the possibility to create clarity in the matter by applying the DIN EN ISO/IEC 17000 standardisation with its further DIN EN standards 17020 and 17025 and the involvement of the DAkkS (German Accreditation Body) in Berlin, bindingly stipulated in a new EU regulation. Of course, it is also necessary that more transparency is brought into the relationship between politics, politicians, parties and ministries to the work and the financial circumstances on the ground, such as in the case of possible “party donations” to surveillance organisations, or also to their in-house foundations, or the Vereinskasse e.V. are paid, thereby, of course, a possible influence on a “non-introduction” of laws could take place, this question is certainly, after what has recently come to light, worth putting. But also the question of the influence of “monitoring organisations” in connection with “interest groups” on competing products and their evaluation, e.g. in the context of a main inspection? Or what influence do “interest groups” have when employees of state “monitoring organisations” are sent to them for “training courses” in which the products of a competitor are presented and trained as not conforming to the law, so that in the case of “sovereign tasks” of the “monitoring organisation”, e.g. in the case of an inspection according to § 29 StVZO, they are then listed as a “defect” or “serious defect” and the customer is sent home as “failed”? We will also look into these questions and find an answer from the legislator and report on it. This is our mission towards our members.
At this point, however, the undersigned would like to close the “Fake News” and “Correction” sections for the moment. You, dear reader, can be assured that the statements made here by the GAGT e.V. are of course all available in writing in legal form and can be inspected at any time. Of course, only GAGT members are allowed to inspect these documents. Any further consultation can also only be permitted to GAGT e.V. members or would have to be paid for by the person asking the question.
The fact that this press release takes up a great deal of space is due to the matter in hand and serves exclusively to provide expert and professional clarification!
Thank you for your attention and remain loyal readers and of course stay… HEALTHY!
gez. Peter Ziegler CEO.
PS. Pure madness…Part IV will follow shortly, we promise, and there we will again deal with “certificates of conformity” and other things.