Ron,
I have great respect for you opinions and thoughfullness in your comments, but as such still have a right to disagree with them and have provided some of my thoughts to your post on the VESC-5 regs by quoting that post and adding my comments in RED inside that quote. A couple of observations in general. The VESC-5 reg you quoted was originally written back in 1968 and underwent two revisions in 1973 and 1977 and this body evidently has not met nor reviewed/revised this document since 1983 - 30 years ago. Thus when originally written and revised such things as the Anderson, Blue Ox, Reese SL, Hensley Arrow, and Propride did not yet exist. It appears the only WDH with some sort of integrated sway might have been the Equal-i-zer and possibly the Pullrite. Thus while I admit one might view it as more authoritative than what I quoted from e-trailer I'm not too sure it is any more accurate than e-trailer's view and not the picture of what they thought was a typical configuration of a two safety chain was with the two chain attachment point "eyelets" on each side of the tongue which to my knowledge no TT uses, but can be found on things such as boat and utility trailers. I guess my point for one to consider is that this VESC-5 document has not been subject to review nor changes considered in over 30 YEARS and could be considered way out of date which is unfortunate since a current and actively reviewed document could be considered much more authoritative.
Here is para 3.9 from the regulation you quoted excerpts from that I think are germane to your quote below and something I will refer to in my comments ....
"Primary Connecting System" means the combination of devices and their attaching structures that are normally utilized to maintain the connections between towing vehicles and trailer during towing operations. This includes, but is not limited to the ball-and-socket type of connection or draft means. NOTE: this does not include a safety chain, which is part of a secondary system normally utilized only upon failure of the primary connection, nor does it included weight distributing or sway control features or devices whose function is accessory to the maintenance of the towing vehicle-trailer connection
This seems to exclude all parts of either the WDH or Sway system such as the Sway bars, brackets, and sway hitch head. It would only include as mentioned in para 3.6 below that you quoted the ball and it's supporting structure which I take to mean the "drawbar" in it's simpliest configuration. I.E. these massive multiple height, extended length drawbars could be considered necessary to support the WDH functions to position the ball properly and not really what is being defined as part of what VESC is defining as the "Primary Connecting System"
Finally before I get into the specific comments on this cargo behind the rear axle on the TV I guess I'm a little more sensitive to it than most where it is a fairly small bit player except maybe in something like the FORD extended 15 passenger Vans. I customized my Van which was basically a cargo van and installed a large secure storage area at the very rear that is 26" deep and all behind the rear axle. It also has a shelf on it and the purpose was to store all my tools and misc stuff inside and use the shelf for taking additional items when towing as the need arose. The weight back there in both the wood for the secure storage structure and the items normally carried in my case are NOT INSIGNIFICANT and I would estimate the total to be between 300 and 600lbs depending on what I have on the top shelf. In fact even with my Van being a cargo Van with the heavy diesel engine up front the normally load on my Van is almost dead on 50/50 between the front and rear axles (3800 on each) which just the basics carried in my secure storage area. Beside a full set of tools, sockets, and even things like two full tool boxes, tap and die set, electric drill, 1/2 in impact wrench, 5 torque wrenches, 4 1/2 in elec. right angle grinder, TIRE CHAINS, a 12T bottle jack, extra oil, tranny oil, diesel fuel supplements, and loads of other stuff at times I have on the shelf had 20gal of diesel fuel, my Honda 2000 and one to two more full tool boxes. NOTE: please non comments on the fuel thing ... I would NEVER RECOMMEND doing what I have and realize it is not safe, but I only used it for like 6 hours at a time mainly when we were attending the Penn State Home football games and I carried the extra fuel from the Flying J in Winchester, Va up to State College and then put it in the Van so I could get back to the Flying J and fuel up on my way home.
Basic secure storage area:

Top shelf of secure storage area:

Anyway on to your quote and my comments ...
Ron Gratz wrote:
Definitions, Definitions, Definitions
For the past seven years, I have been citing
Regulation VESC-5: Min Req for Motor Vehicle Connecting Devices and Towing Methods published by the
Vehicle Equipment Safety Commission (VESC).
All that time, I've assumed that "hitch" in VESC-5 referred to the device which is inserted into the receiver and holds the ball -- what we typically refer to as a "weight distribution hitch".
All that time, I've been searching for a similar regulation or specification which pertains to what I've been calling the "receiver". I've seen receivers which had the V-5 certification, but never was able to find the testing spec.
I decided to take another closer look at VESC-5 to see if I could find any reference to a receiver. I found that, for seven years, I've been overlooking the obvious.
The following are excerpts from VESC-5:
3.6 "Hitch" defined for specific uses under Section 3.6(a. and b. below), generally means that part of the primary connecting system normally mounted on the towing vehicle, including a ball-support platform and those components which are attached to the towing vehicle.
This specifically says the hitch is "NORMALLY" mounted to the towing vehicle and part of the "PRIMARY CONNECTING SYSTEM" and one could I think argue that the WDH sway hitches as they are called are NOT NORMALLY mounted on the towing vehicle, but are added to the receiver temporarily when towing. Further more under section 3.9 all the components of what we normally consider a WDH and integrated Sway system such as the Reese SL, Equal-i-zer, and Blue Ox Sway Pro except for the ball and some minimal drawbar are clearly excluded specifically from the "Primary Connecting System" and thus are no part of the "HITCH" as used in VESC-5. [COLOR]
3.6.a "Weight Distributing Hitch" means a mechanical device that connects the trailer to the towing vehicle and by means of leverage applied on both trailer and towing vehicle structures, when properly adjusted, distributes the imposed vertical load at the hitch and coupling connection between structures of towing vehicle and trailer. The towing vehicle thus tends to retain a level position with respect to the road.
3.6.b "Weight Carrying Hitch" means a mechanical and/or structural device that connects the trailer to the towing vehicle, and that does not employ features designed to redistribute the load imposed at the hitch and coupling connection.---
(bold added for emphasis)
The word, "receiver", is not used. Instead, VESC-5 uses the phrase, "those components which are attached to the towing vehicle".
and we must remember that those components are only those "NORMALLY Mounted" plus specifically the ball and it's supporting structure which I have called the minimalist "drawbar". My Equal-i-zer WDH/Sway system is "NOT NORMALLY" mounted to my tow vehicle only my receiver so for purposes of VESC-5 the hitch components could be interpreted as being only the ball and something to support it. Of course we have no way to resolve this issue of TW rating of the receiver when used in WDH configuration and how it applies to VESC-5 since it appears that VESC-5 sort of ignored all the WDH stuff which as already noted was almost non existent back when this reg was written and revised 36 years ago.
3.8 "Maximum Vertical Load on Hitch (Tongue Weight)" means the vertical downward static force exerted on the hitch by the coupling at the point of connection of coupling and hitch with weight distribution features or devices, if any, deactivated. Tongue weight is measured at the trailer coupling, with the trailer on a level surface (detached from the hitch), and with trailer consumables and cargo in maximum loaded conditions.
5.3 Attachment of Hitch. Each hitch shall be attached to the structural member or members of the towing vehicle---
Indicating that the receiver is an integral part of the hitch assembly.
I guess you could read it that way, but I consider my receiver a part of my vehicle towing Structural member since it's function to the transfer forces at the receiver to the vehicle frame. So again I read the hitch to be narrowly limited to only the ball and the balls support structure (i.e. minimalist drawbar) as defined previously in para 3.6 and 3.9 above.
5.4 Maximum Vertical Load on Hitch (Tongue Weight). The weight load carried by the hitch at its connection with the trailer coupling shall not, when on a level surface, exceed the maximum tongue weight recommended by the manufacturer for the hitch.
I believe this establishes the relationship between receiver rating and tongue weight.
Based solely either on my lack of understanding or common sense I personally can subjectively see several components of these vertical loads as they comprise the tongue weight as defined in 5.4. There are common and unique components in my view for both what the receiver sees as TW in the weight carrying and weight distribution modes. In weight carrying the components are the what I call "dead tongue wt" like what we typically measure with the Sherline scales and what one should consider in the tongue wt. allowance percentage we often quote of 12 to 15% which effects how the trailer handles along with anything above and beyond a simple ball and it's smallest drawbar such as the wt. of the bike rack that e-trailer says has to be added to the TW in their documentation. Similarly if we were to use our WDH and much heavier drawbar w/o an of the WDH or Sway components that wt. over the bare bones connection system necessary in weight carrying mode would count as TW on the hitch. Similarly my opinion is the vertical component of any cargo that is loaded in the TV aft of the rear axle that can be quantified as a vertical force at the point of the ball socket connection could and should be counted as TW when the receiver is used in the weight carrying configuration. The simple reason here is that the function as I see it of the WDH system is to take the non normal forces that are at the "ball/socket" location and distribute them to the axles of the tow and towed vehicles. These forces at the "ball/socket" in my view can come from 3 sources in the case of a weight carrying configuration ... the "dead trailer tongue wt", the weight of the WDH/Sway system in excess of a simple ball and mount, and the component of the cargo wt after the rear axle of the TV.
Page 14. 3. Each hitch, when tested as specified above, shall be capable of withstanding the forces applied in accordance with footnote (2), immediately above, without causing permanent deformation of the ball platform, such that the final position of the ball axis shall not depart more than five degrees from its original, nominally vertical, position.
Obviously, the shank and ball platform are inserted into the receiver prior to test loading -- they are not part of the test loading.
Page A-2 TEST PROTOCOL FOR CONNECTING DEVICES AND TOWING METHODS WITH SUMMARY OF RESULTS
Step 2. Attach the hitch to a non-yielding restraining fixture, utilizing only the attaching means recommended by the manufacturer for hitch-to-car attachment.
Step 4. Attach a ball to the ball support platform in the manner recommended by the manufacturer.
For me, the mystery is solved -- VESC-5 is a specification for simultaneous testing of a complete connecting system consisting of receiver, shank, and ball mount.
The tongue weight rating refers to the vertical load imposed on the ball mount by the trailer coupler.
Others might have a different interpretation of VESC-5.
Ron
You made as I remember a comment about this cargo thing and when it's added or considered and I'm not sure that matters because in my view whatever wt. behind the rear axle that is acting as a lever on the TV to change the wt on the front axle the vertical component of that "CARGO WT" attributed at the ball/coupler location will be redistributed the same way as the additional wt. of just the trailer tongue. Thus to my way of thinking it is the same as tongue wt from a WDH standpoint as the tongue wt. at the trailer coupler.
I felt I need to add my final I think comments and think that it's too bad we don't have better references to more clearly and universally clear up all this and as you said I guess we will just have to agree to disagree.
While my opinion still hasn't changed (maybe old age and subborness has finally permanently routed itself in my personality) I will make an attempt to bookmark this thread and include it via a link in the future if I make any comment concerning this contrary to Ron's view on what should be considered tongue wt. That way future readers can then decide which camp they wish to stay in for the night.
Larry