Question for the smarts on trailers

gov.uk/government/publicati … um-weights wrote:
38000kg if the combination consists of a 2 axle tractor unit and 2 axle semi trailer where the gross weight of the tractor unit does not exceed 18000kg and the gross weight of the semi trailer does not exceed 20000kg. The drive axle must be fitted with twin tyres and road friendly suspension and the trailer axle spacing February 2010 must be at least 1.8m.

How is the gross weight of the trailer going to not exceed 20,000kg and achieve a combination weight of 38,000kg unless the unit weighs a bit under 18,000 kg unladen? This should read “the Total Axle Weights of the trailer do not exceed 20,000kg.”