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Petition for tow hitch on the Model S

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You can tow damn near anything with any vehicle. You just have to forget about warranties and be willing to do the mantainence needed. Years ago I towed a 23 ft cabin cruiser with a 150 hp Pontiac. I had a full equalizer hitch on it 5 gallon radiator and a deal with a transmission shop to rebuild the tranny every 2 years. Didn't have to rebuild the engine til 130,000 miles. A car is a tool. Use it as you need and be prepared for the consequences.

I think this proves your statement. Honda Gold Wing Used as a Tow Truck Is an Epic Sight

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I wonder what the process is for EU type approval for tow hitches, does it involve crash testing etc...?

No, crash tests AFAIK, but things like this:

At the moment a small german company runs the approval procedure for its specially manufactured tow hitch for the Renault ZOE. It costs about the price of one new ZOE. You could do that with the Model S too, but you need someone to eventually develop a tow hitch, initiate the approval procedure and last not least pay it and get it somehow refunded. In the case of the ZOE the company mentioned above will sell its own tow hitch for about 800 € and is already looking for customers on the internet.
 
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to be fair it does seems shame that this is still not resolved.
All I need to tow is the occasional baked load of up to 750kg, So not exactly ground breaking. Even a ford fiesta will do that without issue.
A gap in the design process methinks?