ADR, Tow-Carrier Claims and the Real Risks
ADR, Tow-Carrier Claims & the Real Risks
Why “3.5T Rated” Hitch Carriers Are Often Dangerous Hype

Our Journey
Our journey towards official ADR certification of tow hitch weldments used on our GEN3 and GEN4 carriers began several years ago. We actually initially released a tilting spare tyre carrier that didn't have the ability to tow through it - but the market was quick to request that they could maintain the ability to tow while using this product. It was pretty clear that we needed to innovate a solution or the product wouldn't take off.
We lost a lot of sleep because of this. The idea of allowing people to tow expensive, heavy, trailers and caravans from our hand made products was something pretty daunting.
Years later we were able to engineer, test, and produce repeatably - multiple hitch weldments that achieved the highest reasonable, safe, tow rating of 2T. We set this rating after testing, and discussing the potential risks with our engineer.
"Do you really think its reasonable that people tow 3.5T with these types of products installed, or should they just do it straight from their towbar when towing heavy? Set it at 2T - this gives customers a much safer option."
The fact that we are relying on the existing vehicles down ball and tow hitch ratings made it pretty clear that a 2T rating was the correct choice - this has since been verified by official OEM engineers from multiple vehicle manufacturers behind the scenes - allowing us to distribute these products to users in the government, commercial fleet, and the general public.
Here's a funny story for you - We once received a phonecall from a competitor disguising himself as a prospective buyer. It wasn't too difficult to find out where he was from, using his mobile number through a quick google search.
"Why did you get your products ADR certified, why don't you just give them a manufacturers rating instead".
We answered pretty bluntly - "The product is being used as a towbar, and to legally use a towbar on Australian roads they need to be ADR certified, how are these products any different?"
This particular competitor has since entered the market without ADR certification.
It was becoming clear that compliance wasn't being taken too seriously by our competitors, but we made it a priority - we were pretty sure our customers would appreciate it in the long run.
The Wild West of Hitch-Mounted Cargo Carriers
Recently there has been another wave of competitors entering the market locally, and from international suppliers. The bold claim — “ADR certified to 3.5 tonnes!” — on hitch-mounted spare, cargo, and fuel carriers that plug straight into a vehicle’s towbar.
Sounds impressive… until you look closer at the actual limits set by ADR 62/02, your vehicle’s down-ball rating, and how leverage, dynamic loads, and fatigue all interact with these types of products.
At Mirack Products, we design, test, and manufacture in Australia — and our reputation is built on transparency: real data, real testing, and real safety.
Want to know our honest takeaway? If your hitch-mounted carrier and cargo weigh over 100 kg combined, you simply cannot tow 3.5T safely or legally.
Real Incidents That Prove the Risks of Overloading
Unfortunately, the dangers of pushing towing limits aren’t just theory — they’ve played out on Australian roads many times. Real-world incidents show what can happen when vehicles, tow systems, or accessories are used beyond their safe or certified capacities.
One particular example shared below - while not a hitch carrier causing the crash, its quite similar when considering vehicle weights and ratings.
Fatal Overload Case in NSW (Walcha, 2019):
A driver towing a caravan that was allegedly overweight was involved in a fatal crash.
Police measured the wreckage and charged the driver for “towed vehicle weight exceeding the capacity of the towing attachment.”
Down-Ball Math in Practice
It all comes down to some simple maths.
Let’s take a few real customer examples . 3.5T rated vehicles, and smaller builds like the Subaru Outback and VW Touareg.
Toyota LandCruiser 300
Fitted with our GEN5 Dual Swinging Hitch Carrier, the vehicle having a factory down-ball limit of 350 kg.
Now lets calculate:
• GEN5 Dual Swing Carrier weight ≈ 55 kg
• Cargo (tyre + fuel + brackets) ≈ 90 – 100 kg
That’s already around 150 kg before you hitch a trailer. 350 kg − 150 kg = ≈ 200 kg usable down-ball remaining. Since a trailer’s tongue weight is roughly 10 % of its mass, that equates to a 2 tonne trailer in perfect conditions. Why do competitors think giving this type of product a higher rating is appropriate?

Ford Everest
Fitted with our GEN4 Swinging Spare Wheel Carrier, the vehicle having a factory down-ball limit of 350 kg.
Now lets calculate:
• GEN4 Swinging Carrier weight ≈ 30 kg
• Cargo (tyre + folding table) ≈ 50 – 60 kg
That’s already close to 100 kg before you hitch a trailer. 350 kg − 100 kg = ≈ 250 kg usable down-ball remaining. Since a trailer’s tongue weight is roughly 10 % of its mass, that equates to a 2.5 tonne trailer in perfect conditions with the carrier fully loaded. We would still impose a 2T max rating on this configuration - to take into account the extended tongue length and safety factor considerations.

Subaru Outback
Fitted with our GEN4 Swinging Spare Wheel Carrier, the vehicle having a factory down-ball limit of 200 kg.
Now lets calculate:
• GEN4 Swinging Carrier weight ≈ 30 kg
• Cargo (tyre + folding table) ≈ 50 – 60 kg
That’s already close to 100 kg before you hitch a trailer. 200 kg − 100 kg = ≈ 100 kg usable down-ball remaining. Since a trailer’s tongue weight is roughly 10 % of its mass, that equates to a 1 tonne trailer in perfect conditions with the carrier fully loaded.

Add in bumps, sway, braking, and fatigue, and that margin disappears fast.
These examples are why we rate our hitch carriers at 2T for through-towing — not 3.5T.
Leverage and Moment Arm
As your carrier extends further behind the vehicle, it multiplies the torque on the hitch.
Every extra centimetre of offset means more stress on the towbar mounts and the vehicle chassis.
A 100 mm increase in extension can add hundreds of newton-metres of torque at the coupling.
Even if your load hasn’t changed in weight, the effective force on your mounts increases — and fatigue happens faster.
Tip: keep your setup as close to the towbar face as possible and inspect your hardware regularly.
Safe-Use Checklist
Before you head out, make sure your setup passes this quick audit:
✅ Weigh the carrier and subtract it from your vehicle’s down-ball limit.
✅ Include real cargo mass (tyre, fuel, brackets, etc).
✅ Remember that longer arms mean greater torque at the hitch.
✅ Leave margin for bumps, sway, fatigue, and shock loads.
✅ Stay within GVM / GCM / axle load limits.
✅ If towing more than 2T with rear cargo, use a chassis-mounted rear bar.
✅ Always demand documentation for any “3.5T ADR” claim before you purchase.
Our Philosophy: Safety Before Hype
Mirack’s 2T through-towing rating isn’t a marketing tactic — it’s grounded in physics, math, and real-world testing. In the market for one of these systems and considering your options? Try showing these calculations to anybody claiming 3.5T through-towing while using a loaded hitch carrier. And make sure you are buying the safest possible option for your vehicle.
We design for safety and longevity - not a quick buck. Thats why we've been in business with these carriers for over 10 years and have been trusted by hundreds of customers worldwide.
When you’re towing thousands of kilos behind your vehicle, honesty matters more than hype. If you plan to tow more than 2T while carrying rear cargo, the correct solution is a chassis-mounted rear bar.
© 2025 Mirack Products — Engineered & Manufactured in Australia.