Vehicle categories M, N and O: what makes a truck, a bus or a trailer in law

In Regulation (EU) 2018/858, the European Union’s regulation on the approval and market surveillance of motor vehicles and their trailers, a vehicle of category N is a motor vehicle “designed and constructed primarily for the carriage of goods”, a vehicle of category M is a motor vehicle designed and constructed “primarily for the carriage of passengers and their luggage”, and category O “consists of trailers” (Article 4(1), consolidated text of 2 August 2026). Each category is divided by maximum mass, and M also by seating positions: N3, for example, covers motor vehicles “with a maximum mass exceeding 12 tonnes”. The UN Consolidated Resolution on the Construction of Vehicles (R.E.3), a resolution of the UNECE World Forum WP.29, sets the same categories with the same limits, in kilograms. Lorry, truck, Lkw, kamyon, camión and грузовик are the everyday words for a goods vehicle; where a national text defines one of them, it uses its own terms and limits, compared below.

These are vehicle categories. Driving-licence categories such as C1, C, D1 and D are a separate set of letters, explained in truck driving licences and bus driving licences.

Status as of 8 October 2026. Every text was read on that day, in the version named in the source list: Regulation (EU) 2018/858 consolidated on 2 August 2026 (English, German and Spanish), R.E.3 Revision 7 (English and Russian), the current Turkish texts, Spain’s Reglamento General de Vehículos as last updated on 26 June 2026, the British texts as revised on legislation.gov.uk, and the US Code of Federal Regulations in its edition revised as of 1 October 2025; our search of the Federal Register found no later rule amending the two US sections used. The EU consolidated text “is meant purely as a documentation tool and has no legal effect”, and the Spanish one is “de carácter informativo” (for information only). Turkish and Spanish quotations keep the original words, with our translation in brackets.

Categories M, N and O and their limits

Regulation (EU) 2018/858 uses the categories for EU and national type-approval and for individual vehicle approval (Annex I, Part A, point 1); R.E.3 sets them out in its paragraph 2. The table gives both wordings.

Categories M and N are for vehicles with at least four wheels: R.E.3 says so in the headings of paragraphs 2.2 and 2.3 (“Power-driven vehicles having at least four wheels”), and Regulation (EU) 2018/858 in its definition of a motor vehicle, which also requires “a maximum design speed exceeding 25 km/h” (Article 3(16)). The Regulation’s M2 and M3 apply “regardless of whether those motor vehicles have space for standing passengers”; its M1 is “without space for standing passengers”.

Maximum mass. In Annex I to the Regulation, “‘Maximum mass’ means the ‘technically permissible maximum laden mass’” (introductory part, point 1.4), and “The manufacturer is responsible for the categorisation of a type of vehicle into a specific category” (introductory part, point 3.1). How much a vehicle may weigh on the road is set by other rules, for the EU in Directive 96/53/EC on maximum authorised dimensions and weights; see truck weights.

Towing vehicles and trailers. For a tractor unit for semi-trailer, “the maximum mass to be considered for classifying the vehicle shall include the maximum mass of the semi-trailer borne by the fifth wheel coupling” (Annex I, introductory part, point 2.2.1). For a motor vehicle that can tow a centre-axle trailer or a rigid drawbar trailer, it includes “the maximum mass transferred to the towing vehicle by the coupling” (point 2.2.2). For a semi-trailer, a centre-axle trailer and a rigid drawbar trailer, the mass that counts is “the maximum mass transmitted to the ground by the wheels of an axle or group of axles when coupled to the towing vehicle” (point 2.2.3).

Special equipment. “Vehicles fitted primarily with fixed equipment such as machinery or apparatus shall be regarded as N or O category” (Annex I, introductory part, point 2.3.1). In R.E.3 the equipment and installations carried on certain special purpose vehicles, such as crane, workshop and publicity vehicles, “are regarded as being equivalent to goods” (2.3.4.2).

Goods or passengers: where N1 ends and M1 begins

Whether a van or a pick-up is N1 or M1 is decided by the criteria in Annex I, Part A, point 3 of Regulation (EU) 2018/858; the requirements of points 3.2 to 3.6 “shall be met for all variants and versions within the type of vehicle” (point 3.7):

• Separation. “As a matter of principle, the compartment(s) where all the seating positions are located, shall be completely separated from the loading area” (3.2). Persons and goods may share a compartment if the loading area has securing devices that protect the persons “against the displacement of the load during driving, including severe braking and cornering” (3.3).
• Seats. Excluding the driver’s seating position, at most 6 in an N1 vehicle and 8 in an N2 or N3 vehicle (3.5).
• Payload. “Vehicles shall show a goods-carrying capacity equal or higher than the person-carrying capacity expressed in kg” (3.6). Point 3.6.1 sets equations in which P is the technically permissible maximum laden mass, M the mass in running order and N the number of seating positions excluding the driver’s: P – M ≥ 100 kg when N is 0; P – (M + N × 68) ≥ 150 kg when N is more than 0 and not more than 2; P – (M + N × 68) ≥ N × 68 when N is more than 2.
• Vans. For bodywork BB, where the driver’s compartment and the load are in a single unit, point 3.8.2 adds that loading of the goods must be possible by a rear door, a tailgate or a side door; that with a rear door or a tailgate the loading aperture is at least 600 mm high with one row of seats or only the driver’s seat, or at least 800 mm high with a surface of at least 12,800 cm² with two or more rows; and that the cargo area is generally flat and at least 40 % of the wheelbase long with one row of seats or one seat, or 30 % with two or more rows.

“A vehicle shall be categorised as N1 when all the applicable criteria are met. When one or more of the criteria are not met, the vehicle shall be categorised as M1” (point 3.8.1).

Bus classes and bodywork codes

R.E.3 divides vehicles of categories M2 and M3 by capacity: for more than 22 passengers in addition to the driver there are Classes I, II and III, and for not more than 22 there are Classes A and B (2.2.4). What each class requires is explained in bus classes. R.E.3 also sorts trailers of categories O2, O3 and O4 into three types: the semi-trailer, the full trailer and the centre-axle trailer (2.4.5).

Annex I, Part C of Regulation (EU) 2018/858 adds a two-letter bodywork code, applied “primarily to complete and completed vehicles” (point 1.1).

The lorry, code BA, is “A vehicle that is designed and constructed exclusively or principally for conveying goods. It may also tow a trailer.” The van, BB, is “A lorry with the compartment where the driver is located and cargo area within a single unit”, and the pick-up truck, BE, has “a maximum mass not exceeding 3 500 kg”. The bodies built on semi-trailers, from curtainsiders to low loaders, are described in trailer types, and the brakes of O3 and O4 trailers in trailer brakes and EBS.

The Glossary for transport statistics of Eurostat, the UNECE and the International Transport Forum ties its statistical terms to the R.E.3 categories: a light goods road vehicle has “a gross vehicle weight of not more than 3 500 kg” and includes category N1; a heavy goods road vehicle is above 3 500 kg and “Refers to categories N2 and N3”; and the lorry/truck is a “Rigid road motor vehicle designed, exclusively or primarily, to carry goods”.

Everyday words and the terms in the texts

How national law defines trucks and buses

National texts define vehicles for their own purposes and draw their own lines. The table gives the definitions in the texts read; it compares wording and does not say which vehicle belongs to which category under another text.

Türkiye. Besides defining the N1 sınıfı taşıt (Article 4(1)(bbbb)), the Road Transport Regulation leaves out of its scope carriage in which the goods carried are not commercial, in vehicles “N1 ve N1G araç sınıfında yer alan kamyonet cinsi olarak tescil edilen” (registered as kamyonet in vehicle class N1 or N1G) (Article 2(3)(f)). In the same Regulation, M1, M2, N1 and N2 are also the names of types of authorisation certificate (yetki belgesi) for cargo and nakliyat ambarı operators (Article 6(10) and (11)), a different use of the same letters. Neither Law No. 2918 nor the Regulation contains the word midibüs (our search of both current texts on 8 October 2026).

Spain. Part B divides the construction codes for the camión, the furgón, the autobús and the remolque by masa máxima autorizada (maximum authorised mass). The heading of code 21 ends “MMA ≤ 12.500 kg.” while its text reads “igual o inferior a 12.000 kg” (equal to or less than 12,000 kg); code 22 is “superior a 12.000 kg” (over 12,000 kg). Both figures for code 21 are given here as printed.

United States. The designations of Table II are used “In submitting the required information to NHTSA relating gross vehicle weight rating”, and “The use of these designations within the VIN itself is not required” (49 CFR 565.15). Below Class 3 the table uses letters, Class A to Class H, the last “Greater than 4082 kg. to 4536 kg. (9,001-10,000 lbs.)”; Class 3 is “Greater than 4536 kg. to 6350 kg. (10,001-14,000 lbs.)”. The ratings and the classes are explained in GVWR, GCWR and GAWR.

Great Britain. Section 121 of the Road Traffic Act 1988 defines its terms “In this Part of this Act”, Part IV, on the licensing of drivers of large goods vehicles and passenger-carrying vehicles; the British licence categories are covered in HGV licences in Great Britain. Regulation 3 of the Construction and Use Regulations defines the heavy motor car and the motor car by unladen weight, and the coach as “a large bus with a maximum gross weight of more than 7.5 tonnes and with a maximum speed exceeding 60 mph”. Our search of regulation 3 found no entry for categories M, N or O.