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UK Caravanning (uk.rec.caravanning) A forum for the discussion of caravanning undertaken by residents of the United Kingdom, whether in the UK or abroad. It encourages the interchange of views on the merits of models of caravan, makes of tow car, accessories, caravan sites, caravan clubs, and other related topics. The term caravan is to include trailer vans, motor caravans and trailer tents.

Towing Mirrors



 
 
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  #1 (permalink)  
Old April 30th 08, 10:05 AM posted to uk.rec.caravanning
hugh
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Posts: 1,616
Default Towing Mirrors

Latest CC Magazine had an article on legal requirements for towing
mirrors. But they admitted that their own legal department found it all
too hard and difficult and so they asked a mirror manufacturer!!

Does anyone know of a genuinely unbiassed analysis of the current
requirements regarding "E" approved towing mirrors.
--
hugh
Reply to address is valid at the time of posting
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  #2 (permalink)  
Old April 30th 08, 10:50 AM posted to uk.rec.caravanning
David
external usenet poster
 
Posts: 594
Default Towing Mirrors



"hugh" ] wrote in message
...
Latest CC Magazine had an article on legal requirements for towing
mirrors. But they admitted that their own legal department found it all
too hard and difficult and so they asked a mirror manufacturer!!

Does anyone know of a genuinely unbiassed analysis of the current
requirements regarding "E" approved towing mirrors.
--


Very good question I am wanting the same answer, I did post here a short
while ago. A week ago I e-mailed the CC and they told me the article would
becoming.
I am more confused after reading it!
To me the CC might be going the along with Milenco who have paid advertising
money to them.
I tow with one mirror with e3 on it, so according to Milenco and I think
supported by CC, I have to bin it and buy 2 Milenco new ones with e11 on. I
can't use one any more and it must be Milenco all other makes illegal!

What is CC&C saying?
What do other makers say?

--
Regards,
David

Please reply to News Group

  #3 (permalink)  
Old April 30th 08, 11:19 AM posted to uk.rec.caravanning
Geoff Lane[_2_]
external usenet poster
 
Posts: 178
Default Towing Mirrors

hugh ] wrote in :

Does anyone know of a genuinely unbiassed analysis of the current
requirements regarding "E" approved towing mirrors.


You need to go back to the actual Directives. Some things I can say for
su

You can see the actual legislation for yourself on the OPSI website at
http://www.opsi.gov.uk/si/si2005/uksi_20053165_en.pdf

If your car was first used before June 1978, you can use whatever mirrors
you choose provided they do not make the car dangerous.

All mirrors fitted to cars first used between 1st June 1978 and 25th
January 2010 inclusive must comply with certain requirements of EC
Directive 71/127, 79/795, 86/562, or 88/321, or with paras 4 to 8 of ECE
Regulation 46.01 and paras 2 and 4 of the C&U regs as amended.

As an alternative to the previous requirements, mirrors may comply with the
requirements as to construction and testing set out in -
(a) Annex I to Community Directive 71/127, excluding paragraphs
2.3.4 and 2.6;
(b) Annex I to Community Directive 79/795, excluding paragraphs
2.3.3 and 2.6;
(c) Annex II to Community Directive 2003/97, excluding paragraph
3.4; or
(d) Annex II to Community Directive 2005/27, excluding paragraph
3.4.
Note that compliance with only construction and testing elements is
required, so unless those elements call for marking, a mirror that complies
with (a), (b), (c), or (d) above need not be marked.

My incomplete knowledge doesn't rule out a route to compliance where
marking is not required, but that doesn't mean such a route actually
exists. However, if the requirements to which complaince is claimed do not
require E-marking, then your mirrors don't need to be E-marked. *_but you
need to know to which requirements your mirrors are claimed to conform, and
then check the relevant Directive to ensure that marking is not mandatory_*

That said, if a police officer or other authorised person examines your
mirrors, notes the lack of an E-mark, and forms the opinion that they do
not comply with the law, you're in for a lot of grief. The onus would then
be on you to prove the opinion of the officer to be incorrect - and I
suspect you'd need the manufacturer's testimony together with copies of the
test certificates to prove that. The CC article says that most cases are
dealt with via fixed penalty. Would you really want to risk elevating the
60 plus 3 points fixed penalty to the claimed maximum of 1,000 plus the
points plus both your costs and those of the prosecution?

Pragmatically, then, I guess it doesn't matter whether mirrors strictly
need to be E-marked because an E-mark is the only way of ensuring they'll
pass a roadside inspection.

However, the E-mark shown in the CC article is the latest E-mark. Earlier
E-marks are in a rectangle, not a circle, and are as described in
http://www.conformance.co.uk/logos/e...-mark_logo.php (.) Mirrors
legitimately marked with the earlier, rectangular, mark conform with
Directives other than the latest but are legal on cars first used before a
certain date. The CC article implies this to be 2007, whereas my
interpretation of the regs suggests this to be 26th January 2010.

BTW and for info, the number of the E-mark indicates the country in which
compliance was claimed. For example, E1 = Germany, E2 = France,
E3 = Italy, E11 = UK, and E24 = Ireland.

HTH,

Geoff
  #4 (permalink)  
Old April 30th 08, 11:31 AM posted to uk.rec.caravanning
Geoff Lane[_2_]
external usenet poster
 
Posts: 178
Default Towing Mirrors

"David" wrote in
:

I tow with one mirror with e3 on it, so according to Milenco and I
think supported by CC, I have to bin it and buy 2 Milenco new ones
with e11 on. I can't use one any more and it must be Milenco all
other makes illegal!


No you don't have to bin it! If that e3 mark is legitimate your mirror is
completely legal. The number signifies the member state in which conformity
was claimed. e3 means Italy and e11 means UK. So e3 is to be expected on
mirrors made by Italian companies (like Fiamma)!

Also, AFAICT, the claim that two mirrors are required is not universally
true. Here's what the actual legislation says:

quote
(i) At lease one exterior mirror fitted on the offside of the vehicle; and
(ii) at least one interior mirror, unless a mirror so fitted would give the
driver no view to the rear of the vehicle; and
(iii) at least one exterior mirror fitted on the nearside of the vehicle
unless an interior mirror gives the driver an adequate view to the
rear.
end quote

So, if your interior mirror gives you an adequate view to the rear (which
the CC article implies to be that you can see four metres either side of
the widest point of the outfit at road level at a distance of 20 metres)
you do not require a nearside mirror. That said, I can think of no cases
where an offside towing mirror is required where a nearside mirror would
not be beneficial. An e-marked mirror could cost under a tenner, and it
most certainly doesn't need to be a Milenco!
  #5 (permalink)  
Old April 30th 08, 11:47 AM posted to uk.rec.caravanning
David
external usenet poster
 
Posts: 594
Default Towing Mirrors



"Geoff Lane" wrote in message
7.

No you don't have to bin it! If that e3 mark is legitimate your mirror is
completely legal. The number signifies the member state in which
conformity
was claimed. e3 means Italy and e11 means UK. So e3 is to be expected on
mirrors made by Italian companies (like Fiamma)!


Thanks that good news. ( It is marked as a SMAT nord maker.)

Regarding the nearside it might well be a good idea to get one, just in case
a clever Police officer reads the Milenco or CC reports and assumes I'm
guilty of not having 2.

Thanks

--
Regards,
David

Please reply to News Group

  #6 (permalink)  
Old April 30th 08, 01:55 PM posted to uk.rec.caravanning
DieSea
external usenet poster
 
Posts: 508
Default Towing Mirrors


"David" wrote in message
...


"hugh" ] wrote in message
...
Latest CC Magazine had an article on legal requirements for towing mirrors. But
they admitted that their own legal department found it all too hard and
difficult and so they asked a mirror manufacturer!!

Does anyone know of a genuinely unbiassed analysis of the current requirements
regarding "E" approved towing mirrors.
--


Very good question I am wanting the same answer, I did post here a short while
ago. A week ago I e-mailed the CC and they told me the article would becoming.
I am more confused after reading it!
To me the CC might be going the along with Milenco who have paid advertising
money to them.
I tow with one mirror with e3 on it, so according to Milenco and I think
supported by CC, I have to bin it and buy 2 Milenco new ones with e11 on. I
can't use one any more and it must be Milenco all other makes illegal!

What is CC&C saying?
What do other makers say?

--
Regards,
David

Please reply to News Group


I bought a couple of **Cheapies** from a local dealer to fit on the Disco mirrors
a week ago

When I got them home , guess what , no markings whatsoever

They've got a shed load of these mirrors

Should I tell Trading Standards ,

I think not , I don't want Alison breathing down my neck

I think I'll chicken out and let some one else do that !!

DieSea


  #7 (permalink)  
Old April 30th 08, 06:09 PM posted to uk.rec.caravanning
puffernutter
external usenet poster
 
Posts: 20
Default Towing Mirrors

snip

Please reply to News Group


I bought a couple of **Cheapies** from a local dealer to fit on the Disco mirrors
a week ago

When I got them home , guess what , no markings whatsoever

They've got a shed load of these mirrors

Should I tell Trading Standards ,

I think not , I don't want Alison breathing down my neck

I think I'll chicken out and let some one else do that !!

DieSea


Like a lot of things, it's not illegal to sell them, just to use them!

Cheers

Peter
  #8 (permalink)  
Old April 30th 08, 06:38 PM posted to uk.rec.caravanning
DieSea
external usenet poster
 
Posts: 508
Default Towing Mirrors


"puffernutter" wrote in message
...
snip

Please reply to News Group


I bought a couple of **Cheapies** from a local dealer to fit on the Disco
mirrors a week ago

When I got them home , guess what , no markings whatsoever

They've got a shed load of these mirrors

Should I tell Trading Standards ,

I think not , I don't want Alison breathing down my neck

I think I'll chicken out and let some one else do that !!

DieSea

Like a lot of things, it's not illegal to sell them, just to use them!

Cheers

Peter


A fortnight ago this hadn't raised its head

There is a similar discussion going on in another news group

Its an easy cop for the **Plod**

Photograph of car and trailer , no arguments !!

60 quid and 3 points

I am surprised that the Caravan Club's legal department took an way to cop out
though

DieSea


  #9 (permalink)  
Old April 30th 08, 08:26 PM posted to uk.rec.caravanning
Geoff Lane[_2_]
external usenet poster
 
Posts: 178
Default Towing Mirrors

puffernutter wrote in news:cB2Sj.58202
:

Like a lot of things, it's not illegal to sell them, just to use them!


I wouldn't be too sure of that. According to the CC article, you can be
prosecuted for aiding and abbetting if someone uses the illegal mirrors you
sell. Surely, if you sell those mirrors for towing, you're guilty before
the fact of incitement to commit the same crime you would be guilty of
aiding and abetting after the fact.

Then again, if you were to sell the mirrors as towing mirrors, surely you
would also be guilty of selling merchandise that was unfit for purpose and
so would have violated the Sale of Goods Act.
  #10 (permalink)  
Old April 30th 08, 10:55 PM posted to uk.rec.caravanning
puffernutter
external usenet poster
 
Posts: 20
Default Towing Mirrors

Geoff Lane wrote:
puffernutter wrote in news:cB2Sj.58202
:

Like a lot of things, it's not illegal to sell them, just to use them!


I wouldn't be too sure of that. According to the CC article, you can be
prosecuted for aiding and abbetting if someone uses the illegal mirrors you
sell. Surely, if you sell those mirrors for towing, you're guilty before
the fact of incitement to commit the same crime you would be guilty of
aiding and abetting after the fact.

Then again, if you were to sell the mirrors as towing mirrors, surely you
would also be guilty of selling merchandise that was unfit for purpose and
so would have violated the Sale of Goods Act.


But the CC article was written by a mirror manufacturer, so it isn't
exactly an "unbiased" view. If I were them I would take every
(creative) opportunity to make the punters think they needed new mirrors....

I am actually disappointed and disgusted with the CC that;

Disappointed:
1. They didn't see this coming and their "legal" department can't appear
to understand the legislation;

Disgusted:
2. They publish such a blatant marketing article from a mirror
manufacturer, who "just" happens to supply "E-marked" mirrors and the
only example in the article is E11 (Approved by the UK). They don't
make it clear than ANY "E-marked mirror" is OK.

Cheers

Peter
 



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