From the Towsure Website:

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If your car* is registered on or after 1st August 1998 and you fit a towbar, it MUST by law be approved to EC94/20 and installed correctly according to the manufacturers' instructions. It is an offence under the vehicle Construction & Use Regulations to fit, use or permit to be used, a non-approved towbar on the vehicle

* The regulations apply to Passenger carrying vehicles up to 3500kg Gross Vehicle Weight. Light commercial vehicles are not covered by this requirement, so for instance a Ford Transit van is not required to have a Type Approved towbar even if registered after August 1998.
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I have a Scudo with a drop floor so I can't get a regular towbar - so I was thinking about getting one fabricated. I think this should be OK unless the change in a V5C classification takes it away from being a Light Goods Vehicle.

Any thoughts?

It appears that you could be OK.
Often the vehicle handbook will have a diagram showing towbar mounting points. If you can fabricate something still using those, all should be well. If you can't use the recommended locations, a lot of care needs to be taken as wrong loadings can cause flexing or cracking of the structure. That is one reason why the type approval requirement was introduced. The bumper brackets may not be suitable, or not on their own.

portland_bill said:

It appears that you could be OK.
Often the vehicle handbook will have a diagram showing towbar mounting points. If you can fabricate something still using those, all should be well. If you can't use the recommended locations, a lot of care needs to be taken as wrong loadings can cause flexing or cracking of the structure. That is one reason why the type approval requirement was introduced. The bumper brackets may not be suitable, or not on their own.

Click to expand...

Yeah, I suspect the original towbar mount points are still in place becuase it's only the central third of the width that has been lowered - most towbars I have seen mount near the sides.

So basically, use these points and get an OTT fabrication to come out the back and around the dropped floor IYSWIM