Dear John,
many thanks for making me an inquiry. Unfortunately in Spain laws are not like you the perceived. In fact, the laws of the road apply only to movement and parking of an empty caravan, as a vehicle. But using a motorhome as accommodation is considered under the laws governing same camping. These laws are different in the 17 autonomous communities of Spain who have independence to enact these laws.
There are also laws that prohibit using a motorhome as accommodation in the area from the coast by a law regulating the use of a dividing strip on the coast. Mainly in Spain prohibition is to spend the night outside a camping protecting the interests of businessmen of camping. In fact, except in the Basque Country and Navarre, spend the night in a motorhome is not legal. But these rules only apply in some locations, in most of the Spanish territory is allowed to stay overnight in a motorhome, but not because it is a right protected by law. The risk of being denounced and punished economically there, especially on the coast.
The application of laws on camping is used strictly in Asturias, Cantabria and some towns of the coast of the Mediterranean Sea. The municipal areas for motorhomes are exceptions. Instruction 08 / V-74 has no application absolutely in the use of motorhomes as accommodation, only applies to parking under the laws of the road. This is possible in Spain for independence in the regions to make laws on issues such as camping.
Europe
I know, there have been a couple of appeals to the Chamber in the European Union in Brussels about the unification of criteria among member countries on the use of motorhomes as accommodation. The response has been that it is a domestic issue that should regulate each country.
I feel have seemed pessimistic because the legal answer is negative in Spain especially for Spanish campers although enforcement of the laws on camping is not very strict, however, every year a few hundred penalties which will occur up to 400,00 €.
Sincerely, Arsenio Gutiérrez
