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date: Wed, 30 Apr 2008 11:05:48 +0100,    group: uk.rec.caravanning        back       
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
date: Wed, 30 Apr 2008 11:05:48 +0100   author:   hugh

Re: Towing Mirrors   
"hugh"  wrote in message 
news:vSPjTiB8REGIFA+3@raefell.demon.co.uk...
> 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
date: Wed, 30 Apr 2008 10:50:22 GMT   author:   David

Re: Towing Mirrors   
hugh  wrote in news:vSPjTiB8REGIFA+3@raefell.demon.co.uk:

> 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 
sure:

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/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
date: Wed, 30 Apr 2008 06:19:18 -0500   author:   Geoff Lane lid

Re: Towing Mirrors   
"David"  wrote in
news:O9YRj.89044$jH5.61405@newsfe3-win.ntli.net: 

> 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!
date: Wed, 30 Apr 2008 06:31:34 -0500   author:   Geoff Lane lid

Re: Towing Mirrors   
"Geoff Lane" <geoff@nospam.invalid> wrote in message 
news:Xns9A907F6C6F9B7geoffnospam097akdsh@138.199.67.

> 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
date: Wed, 30 Apr 2008 11:47:20 GMT   author:   David

Re: Towing Mirrors   
"David"  wrote in message 
news:O9YRj.89044$jH5.61405@newsfe3-win.ntli.net...
>
>
> "hugh"  wrote in message 
> news:vSPjTiB8REGIFA+3@raefell.demon.co.uk...
>> 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
date: Wed, 30 Apr 2008 14:55:38 +0100   author:   DieSea mm

Re: 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
date: Wed, 30 Apr 2008 19:09:13 +0100   author:   puffernutter

Re: Towing Mirrors   
"puffernutter"  wrote in message 
news:cB2Sj.58202$Q95.49624@newsfe23.ams2...
> <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
date: Wed, 30 Apr 2008 19:38:10 +0100   author:   DieSea mm

Re: Towing Mirrors   
puffernutter  wrote in news:cB2Sj.58202
$Q95.49624@newsfe23.ams2:

> 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.
date: Wed, 30 Apr 2008 15:26:04 -0500   author:   Geoff Lane lid

Re: Towing Mirrors   
Geoff Lane wrote:
> puffernutter  wrote in news:cB2Sj.58202
> $Q95.49624@newsfe23.ams2:
> 
>> 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
date: Wed, 30 Apr 2008 23:55:06 +0100   author:   puffernutter

Re: Towing Mirrors   
"puffernutter"  wrote in message 
news:eN6Sj.7$Tl5.2@newsfe18.ams2...

>
> 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.
>

This is what the CC said to me,
"Thank you for your e-mail.



Milenco are quite correct. Towing mirrors are required to conform to the E11 
mark. UK Law states that the driver must be able to see clearly down both 
sides of the caravan and 4 metres either side at a distance of 20 metres 
behind the caravan. More detailed information can be found in next months 
edition of The Club's Magazine.
Regards

Information Department "

So it is quite clear the CC want us to have e11 and a pair.
So my e3 made in Italy to them or not to used legally in the UK.

-- 
Regards,
David

Please reply to News Group
date: Thu, 01 May 2008 06:10:24 GMT   author:   David

Re: Towing Mirrors   
In message , Geoff 
Lane <geoff@nospam.invalid> writes
>puffernutter  wrote in news:cB2Sj.58202
>$Q95.49624@newsfe23.ams2:
>
>> 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.
There are other examples of things that are not illegal to sell but are 
illegal to use - and I don't recall anyone being prosecuted in this way.
-- 
hugh
Reply to address is valid at the time of posting
date: Thu, 1 May 2008 16:03:51 +0100   author:   hugh

Re: Towing Mirrors   
Geoff Lane wrote:
<snip>

the more I read, the more confused I get...
I have no idea who made my mirrors, or when, but they do have e3 written on 
them, and they are at least 7 years old (I can't remember the shape of the 
box).
My mirrors hang off the windows, with a big elastic strap fastening under 
the doors, and the mirrors themselves are on 18" or so arms so I can extend 
them well beyond the sides of the car, I'm assuming this makes me legal? I 
really don't fancy buying new mirrors as I like the ones I have, they're 
quite funky, and I've never seen another pair!
Tony
date: Thu, 1 May 2008 16:33:16 +0100   author:   tony h

Re: Towing Mirrors   
"tony h"  wrote in news:fvcnu0$13k3$1@energise.enta.net:

> I have no idea who made my mirrors, or when, but they do have e3
> written on them, and they are at least 7 years old (I can't remember
> the shape of the box).
> My mirrors hang off the windows, with a big elastic strap fastening
> under the doors, and the mirrors themselves are on 18" or so arms so I
> can extend them well beyond the sides of the car, I'm assuming this
> makes me legal? I really don't fancy buying new mirrors as I like the
> ones I have, they're quite funky, and I've never seen another pair!

Sounds like Smat Holiday or similar to me. Smats were the first mirrors I 
bought nearly thirty years ago. The elastic strap used to make the most 
awful noise and I drove everywhere with a piece of chamois leather wedged 
between the strap and the door to act as a silencer!

Your mirrors have an "e3" enclosed in a rectangle? If so, this means the 
mirror is legal and was declared compliant in Italy.

Geoff
date: Thu, 01 May 2008 11:06:43 -0500   author:   Geoff Lane lid

Re: Towing Mirrors   
"Jayne"  wrote in news:67u7b4F2qclqpU1
@mid.individual.net:

> For those who want to be pedantic about the markings on the mirrors:
> 'e' in a rectangle signifies approval to the EC Directives; and
> 'E' in a circle signifies approval to the UNECE Regulation.

Thanks for that. I had assumed the circle to indicate compliance with the 
latest Directive, but this changes things.

BTW, I did ask someone else in the trade for a copy of that message, but 
they told me they were under strict instructions not to publish it - 
especially on the Internet. So I thank you for doing it, even though I 
don't think DfT will be best pleased!

Geoff
date: Thu, 01 May 2008 11:21:09 -0500   author:   Geoff Lane lid

Re: Towing Mirrors   
"Geoff Lane" <geoff@nospam.invalid> wrote in message 
news:Xns9A91B08502845geoffnospam097akdsh@138.199.67.64...
> "Jayne"  wrote in news:67u7b4F2qclqpU1
> @mid.individual.net:
>
>> For those who want to be pedantic about the markings on the mirrors:
>> 'e' in a rectangle signifies approval to the EC Directives; and
>> 'E' in a circle signifies approval to the UNECE Regulation.
>
> Thanks for that. I had assumed the circle to indicate compliance with the
> latest Directive, but this changes things.
>
> BTW, I did ask someone else in the trade for a copy of that message, but
> they told me they were under strict instructions not to publish it -
> especially on the Internet. So I thank you for doing it, even though I
> don't think DfT will be best pleased!
>
> Geoff

Whoops!  I didn't receive that bit.......  Although I don't see what is so 
secret about it.

Jayne
date: Thu, 1 May 2008 17:23:37 +0100   author:   Jayne

Re: Towing Mirrors   
"Jayne"  wrote in
news:67u93iF2p0kr9U1@mid.individual.net: 

> Whoops!  I didn't receive that bit.......  Although I don't see what
> is so secret about it.

AIUI, DfT were worried it would open the floodgates to thousands of 
caravanners seeking clarification about the FUD!
date: Thu, 01 May 2008 12:03:14 -0500   author:   Geoff Lane lid

Re: Towing Mirrors   
"Geoff Lane" <geoff@nospam.invalid> wrote in message 
news:Xns9A91B7A77A6D5geoffnospam097akdsh@138.199.67.64...
> "Jayne"  wrote in
> news:67u93iF2p0kr9U1@mid.individual.net:
>
>> Whoops!  I didn't receive that bit.......  Although I don't see what
>> is so secret about it.
>
> AIUI, DfT were worried it would open the floodgates to thousands of
> caravanners seeking clarification about the FUD!

Well, perhaps they should clarify things better in the first place.  You 
would not believe the amount of customers who have been asking if our 
mirrors are "legal", not to mention phone calls.

Jayne
date: Thu, 1 May 2008 18:30:56 +0100   author:   Jayne

Re: Towing Mirrors   
"Jayne"  wrote in message
news:67u7b4F2qclqpU1@mid.individual.net...
>
> "hugh"  wrote in message
> news:vSPjTiB8REGIFA+3@raefell.demon.co.uk...
>> 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
>
> Hi,
>
> I only lurk in this group, but I received an e-mail today which might help. (I
> work in a camping shop and we have been asked about this and have passed the
> question on to our suppliers).  Our suppliers e-mailed the Dept of Transport
> and received a reply as follows:
>
> Regards
> Jayne
> (copy of e-mail text below)
> ----------------------------------------------------
>
> The requirements for caravan towing mirrors follow the vehicle mirror
> requirements as defined in Regulation 33 of the Road Vehicles (Construction and
> Use) Regulations 1986.  Regulation 33 requires that the mirrors comply with
> either the EC Directives (71/127/EEC or 2003/97/EC) or UNECE Regulation 46.
>
> The current confusion is based on the fact that that Regulation 33 allows
> compliance with EC Directive 2003/97/EC.  However, the requirements of this
> Directive do not become compulsory for new cars until 26th January 2010.
> Therefore, if the towing-mirror is already in use, or newly purchased now - E
> marking is preferred (but not strictly required).
>
> If a NEW car is purchased after 26th January 2010, then 2003/97/EC or UNECE
> Regulation 46 compliant caravan towing mirrors will be required for that
> vehicle.  We assume that all caravan towing mirrors would comply with the new
> requirements by that time.
>
> For those who want to be pedantic about the markings on the mirrors:
> 'e' in a rectangle signifies approval to the EC Directives; and
> 'E' in a circle signifies approval to the UNECE Regulation.
>
> Either of these markings is acceptable.
>
> I trust this helps.
>
> Kind Regards
>
> Brian
>
> Brian Greenway
> Department for Transport
> Transport Technology and Standards 8
> Zone 2/05
> Great Minster House
> 76 Marsham Street
> London SW1P 4DR
>
> Tel:  020 7944 2115
> Fax: 020 7944 2196
>

Thanks Jayne

My Brass not down the drain then

DieSea
date: Thu, 1 May 2008 18:53:25 +0100   author:   DieSea mm

Re: Towing Mirrors   
Geoff Lane wrote:
> "tony h"  wrote in news:fvcnu0$13k3$1@energise.enta.net:
>
>> I have no idea who made my mirrors, or when, but they do have e3
>> written on them, and they are at least 7 years old (I can't remember
>> the shape of the box).
>> My mirrors hang off the windows, with a big elastic strap fastening
>> under the doors, and the mirrors themselves are on 18" or so arms so
>> I can extend them well beyond the sides of the car, I'm assuming this
>> makes me legal? I really don't fancy buying new mirrors as I like the
>> ones I have, they're quite funky, and I've never seen another pair!
>
> Sounds like Smat Holiday or similar to me. Smats were the first
> mirrors I bought nearly thirty years ago. The elastic strap used to
> make the most awful noise and I drove everywhere with a piece of
> chamois leather wedged between the strap and the door to act as a
> silencer!
>
> Your mirrors have an "e3" enclosed in a rectangle? If so, this means
> the mirror is legal and was declared compliant in Italy.
>

thanks for that, the noise depends on the car, i had a volvo and it was 
awful at speed, now i drive ssangyongs and the mirrors are lovely and quiet
date: Thu, 1 May 2008 19:43:02 +0100   author:   tony h

Re: Towing Mirrors   
"Jayne"  wrote in news:67ud19F2q7453U1
@mid.individual.net:

> Well, perhaps they should clarify things better in the first place.  You 
> would not believe the amount of customers who have been asking if our 
> mirrors are "legal", not to mention phone calls.

AFAICT it's not DfT who muddied the water. This seems to have started with 
some FUD Milenco put on their website and in an advert in last month's CC 
magazine. Prior to then everyone who bought their mirrors from a reputable 
source presumed (usually correctly) that they were legal.

The CC were allegedly deluged with member enquiries about the subject and 
in response produced a "Q&A" article in this month's magazine. My research 
so far sheds some serious doubt on the accuracy of that article and (as a 
CC member) I intend taking the matter up with them.

Geoff
date: Thu, 01 May 2008 15:34:50 -0500   author:   Geoff Lane lid

Re: Towing Mirrors   
In an earlier contribution to this discussion,
tony h   wrote:

> Geoff Lane wrote:
> <snip>
>
> the more I read, the more confused I get...
> I have no idea who made my mirrors, or when, but they do have e3
> written on them, and they are at least 7 years old (I can't remember
> the shape of the box).
> My mirrors hang off the windows, with a big elastic strap fastening
> under the doors, and the mirrors themselves are on 18" or so arms so
> I can extend them well beyond the sides of the car, I'm assuming this
> makes me legal? I really don't fancy buying new mirrors as I like the
> ones I have, they're quite funky, and I've never seen another pair!
> Tony

Snap - I've got one exactly like that, which I use on the driver's side. The 
distance from the window to the bottom of the door on my current car is too 
great for the elastic strap to fit comfortably without excess stretching - 
so I have joined a piece of leather strap to the top of it to extend it, and 
it works a treat. God only knows what my engineering mods do the EU 
approval! For added stability, I always brace its arm against the car's door 
mirror, using gaffer tape.

On the nearside, I have a mirror which has two hinged arms with a spring 
pulling them together. The bottom arm hooks under the top of the wheel-arch. 
the top arm has a plastic bit at the end which gets trapped under the edge 
of the bonnet. The mirror itself is identical to the driver side one (both 
with E3 markings on the back), and almost certainly made by the same 
manufacturer. I've had to re-engineer that too, by fitting a shorter 
spring - 'cos the wheel-arch to bonnet distance on my current car is a lot 
less than on the car I had when I first bought the mirror many years ago.

In the light of the latest info from the DfT, it looks like I'm probably 
legal. But I don't really care! If you fit extended mirrors both sides which 
give a reasonable view down both sides of the outfit, does anyone seriously 
think that Plod will be geared up to determine whether you've got *exactly* 
the right marking or not?
-- 
Cheers,
Roger
______
Email address maintained for newsgroup use only, and not regularly
monitored.. Messages sent to it may not be read for several weeks.
PLEASE REPLY TO NEWSGROUP!
date: Thu, 1 May 2008 21:46:40 +0100   author:   Roger Mills

Re: Towing Mirrors   
"Roger Mills"  wrote in
news:67uohgF2qbl0pU1@mid.individual.net: 

>  does anyone seriously 
> think that Plod will be geared up to determine whether you've got
> *exactly* the right marking or not?

Not plod, but VOSA (whose sole purpose in life seems to be the checking of 
vehicles and documents) is a different matter.

Now that DfT have clarified that one or more routes to compliance exist 
that do not require e-marking, I suspect they'd need to positively identify 
the mirror as an illegal type. That said, I shudder to think of the 
consequences if the FUD that started this takes root at VOSA. It wouldn't 
be the first time a jobsworth official has unjustly taken action against 
the driver of a perfectly legal outfit!
date: Thu, 01 May 2008 16:41:16 -0500   author:   Geoff Lane lid

Re: Towing Mirrors   
I too am very confused by the article in the CC Magazine, I use the Pyramid 
Stick On mirrors, the best towing mirrors I have ever had, but the only 
marking on them says Pat Pending, I cannot find an E-mark.

These were recommended by the CC in a towing mirror comparison article in 
their July 2005 magazine although I already owned mine at the time. 
According to the article in this month's CC magazine all towing mirrors 
should have been E-mark since 1/3/71, "reasonable to assume if the mirrors 
were not E-marked then they did not comply". The article in July 2005 makes 
no mention of E-marks so were they not aware at this time of the regulation?

I am reluctant to throw away a perfectly good pair of mirrors just because 
they haven't got an E-mark on them. Equally I am reluctant to fork out 
another £50 just to get a pair of mirrors with an E-mark.

Tony Falla


"David"  wrote in message 
news:O9YRj.89044$jH5.61405@newsfe3-win.ntli.net...
>
>
> "hugh"  wrote in message 
> news:vSPjTiB8REGIFA+3@raefell.demon.co.uk...
>> 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
date: Fri, 2 May 2008 12:07:41 +0100   author:   Tony Falla

Re: Towing Mirrors   
"Tony Falla"  wrote in
news:392dnc5t7pSea4fVnZ2dnUVZ8sqjnZ2d@pipex.net: 

> I too am very confused by the article in the CC Magazine, I use the
> Pyramid Stick On mirrors, the best towing mirrors I have ever had, but
> the only marking on them says Pat Pending, I cannot find an E-mark.
> 
> These were recommended by the CC in a towing mirror comparison article
> in their July 2005 magazine although I already owned mine at the time.
> According to the article in this month's CC magazine all towing
> mirrors should have been E-mark since 1/3/71, "reasonable to assume if
> the mirrors were not E-marked then they did not comply". The article
> in July 2005 makes no mention of E-marks so were they not aware at
> this time of the regulation? 
> 
> I am reluctant to throw away a perfectly good pair of mirrors just
> because they haven't got an E-mark on them. Equally I am reluctant to
> fork out another œ50 just to get a pair of mirrors with an E-mark.

Tony,

Look at the message from DfT that Jayne published. Probably the most 
telling bit is:

  "Therefore, if the towing-mirror is already in use, or newly
   purchased now - E marking is preferred (but not strictly
   required)."

So, the lack of an e-mark doesn't mean your mirrors are illegal, and it 
is most certainly not reasonable to assume that an unmarked mirror 
doesn't comply.

I've just spoken to Pyramid, and they tell me they're now e-marking 
their mirrors. The approval numbers are [e11] 46R-02616300 for the "Suck 
it and See" and [e11] 46R-02616200 for the "Rock Steady". They also say 
that DfT have confirmed those mirrors are legal even if unmarked.

HTH,

Geoff
date: Fri, 02 May 2008 07:19:18 -0500   author:   Geoff Lane lid

Re: Towing Mirrors   
Thanks, information crossed I had also e-mailed Pyramid who as you say 
confirm that DfT say mirrors do not have to be marked to still be legal.

Tony

"Geoff Lane" <geoff@nospam.invalid> wrote in message 
news:Xns9A92878406D9Fgeoffnospam097akdsh@138.199.67.64...
> "Tony Falla"  wrote in
> news:392dnc5t7pSea4fVnZ2dnUVZ8sqjnZ2d@pipex.net:
>
>> I too am very confused by the article in the CC Magazine, I use the
>> Pyramid Stick On mirrors, the best towing mirrors I have ever had, but
>> the only marking on them says Pat Pending, I cannot find an E-mark.
>>
>> These were recommended by the CC in a towing mirror comparison article
>> in their July 2005 magazine although I already owned mine at the time.
>> According to the article in this month's CC magazine all towing
>> mirrors should have been E-mark since 1/3/71, "reasonable to assume if
>> the mirrors were not E-marked then they did not comply". The article
>> in July 2005 makes no mention of E-marks so were they not aware at
>> this time of the regulation?
>>
>> I am reluctant to throw away a perfectly good pair of mirrors just
>> because they haven't got an E-mark on them. Equally I am reluctant to
>> fork out another o50 just to get a pair of mirrors with an E-mark.
>
> Tony,
>
> Look at the message from DfT that Jayne published. Probably the most
> telling bit is:
>
>  "Therefore, if the towing-mirror is already in use, or newly
>   purchased now - E marking is preferred (but not strictly
>   required)."
>
> So, the lack of an e-mark doesn't mean your mirrors are illegal, and it
> is most certainly not reasonable to assume that an unmarked mirror
> doesn't comply.
>
> I've just spoken to Pyramid, and they tell me they're now e-marking
> their mirrors. The approval numbers are [e11] 46R-02616300 for the "Suck
> it and See" and [e11] 46R-02616200 for the "Rock Steady". They also say
> that DfT have confirmed those mirrors are legal even if unmarked.
>
> HTH,
>
> Geoff
date: Fri, 2 May 2008 17:41:02 +0100   author:   Tony Falla

Re: Towing Mirrors   
In message , Geoff 
Lane <geoff@nospam.invalid> writes
>"Tony Falla"  wrote in
>news:392dnc5t7pSea4fVnZ2dnUVZ8sqjnZ2d@pipex.net:
>
>> I too am very confused by the article in the CC Magazine, I use the
>> Pyramid Stick On mirrors, the best towing mirrors I have ever had, but
>> the only marking on them says Pat Pending, I cannot find an E-mark.
>>
>> These were recommended by the CC in a towing mirror comparison article
>> in their July 2005 magazine although I already owned mine at the time.
>> According to the article in this month's CC magazine all towing
>> mirrors should have been E-mark since 1/3/71, "reasonable to assume if
>> the mirrors were not E-marked then they did not comply". The article
>> in July 2005 makes no mention of E-marks so were they not aware at
>> this time of the regulation?
>>
>> I am reluctant to throw away a perfectly good pair of mirrors just
>> because they haven't got an E-mark on them. Equally I am reluctant to
>> fork out another œ50 just to get a pair of mirrors with an E-mark.
>
>Tony,
>
>Look at the message from DfT that Jayne published. Probably the most
>telling bit is:
>
>  "Therefore, if the towing-mirror is already in use, or newly
>   purchased now - E marking is preferred (but not strictly
>   required)."
>
>So, the lack of an e-mark doesn't mean your mirrors are illegal, and it
>is most certainly not reasonable to assume that an unmarked mirror
>doesn't comply.
>
>I've just spoken to Pyramid, and they tell me they're now e-marking
>their mirrors. The approval numbers are [e11] 46R-02616300 for the "Suck
>it and See" and [e11] 46R-02616200 for the "Rock Steady". They also say
>that DfT have confirmed those mirrors are legal even if unmarked.
>
>HTH,
>
>Geoff
Might be worth e-mailing the info from Pyramid to the CC and asking them 
to publish it in their next magazine
-- 
hugh
Reply to address is valid at the time of posting
date: Sat, 3 May 2008 20:33:24 +0100   author:   hugh

Re: Towing Mirrors   
In message , Jayne 
 writes
>
>"hugh"  wrote in message
>news:vSPjTiB8REGIFA+3@raefell.demon.co.uk...
>> 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
>
>Hi,
>
>I only lurk in this group, but I received an e-mail today which might help.
>(I work in a camping shop and we have been asked about this and have passed
>the question on to our suppliers).  Our suppliers e-mailed the Dept of
>Transport  and received a reply as follows:
>
>Regards
>Jayne
>(copy of e-mail text below)
>----------------------------------------------------
>
>The requirements for caravan towing mirrors follow the vehicle mirror
>requirements as defined in Regulation 33 of the Road Vehicles (Construction
>and Use) Regulations 1986.  Regulation 33 requires that the mirrors comply
>with either the EC Directives (71/127/EEC or 2003/97/EC) or UNECE Regulation
>46.
>
>The current confusion is based on the fact that that Regulation 33 allows
>compliance with EC Directive 2003/97/EC.  However, the requirements of this
>Directive do not become compulsory for new cars until 26th January 2010.
>Therefore, if the towing-mirror is already in use, or newly purchased now -
>E marking is preferred (but not strictly required).
>
>If a NEW car is purchased after 26th January 2010, then 2003/97/EC or UNECE
>Regulation 46 compliant caravan towing mirrors will be required for that
>vehicle.  We assume that all caravan towing mirrors would comply with the
>new requirements by that time.
>
>For those who want to be pedantic about the markings on the mirrors:
>'e' in a rectangle signifies approval to the EC Directives; and
>'E' in a circle signifies approval to the UNECE Regulation.
>
>Either of these markings is acceptable.
>
>I trust this helps.
>
>Kind Regards
>
>Brian
>
>Brian Greenway
>Department for Transport
>Transport Technology and Standards 8
>Zone 2/05
>Great Minster House
>76 Marsham Street
>London SW1P 4DR
>
>Tel:  020 7944 2115
>Fax: 020 7944 2196
>
>
Please send it to the CC
-- 
hugh
Reply to address is valid at the time of posting
date: Sat, 3 May 2008 20:36:37 +0100   author:   hugh

Re: Towing Mirrors   
Reading through the early part of this thread I was thinking "sod it more 
expense", by the end I am feeling angry with Milenco (mental note to avoid 
their products for pissing us all off!) and a trip out to my aging caravan 
to satisfy my curiosity as to what is on my mirrors which I keep in the van 
when not in use. Result the mirrors are years old,.claim they are 
manufactured in the UK by Radyout (do they exist anymore?) but proudly bear 
the E11 in a box.

Well thats alright then (although the straps are beginning to look a bit 
suspect!).

Moral look carefully at your mirrors before replacing they may well be 
alright even if you purchase a new towcar after 2010.

Peter
"hugh"  wrote in message 
news:ZMgOkREF7LHIFAAW@raefell.demon.co.uk...
> In message , Jayne 
>  writes
>>
>>"hugh"  wrote in message
>>news:vSPjTiB8REGIFA+3@raefell.demon.co.uk...
>>> 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
>>
>>Hi,
>>
>>I only lurk in this group, but I received an e-mail today which might 
>>help.
>>(I work in a camping shop and we have been asked about this and have 
>>passed
>>the question on to our suppliers).  Our suppliers e-mailed the Dept of
>>Transport  and received a reply as follows:
>>
>>Regards
>>Jayne
>>(copy of e-mail text below)
>>----------------------------------------------------
>>
>>The requirements for caravan towing mirrors follow the vehicle mirror
>>requirements as defined in Regulation 33 of the Road Vehicles 
>>(Construction
>>and Use) Regulations 1986.  Regulation 33 requires that the mirrors comply
>>with either the EC Directives (71/127/EEC or 2003/97/EC) or UNECE 
>>Regulation
>>46.
>>
>>The current confusion is based on the fact that that Regulation 33 allows
>>compliance with EC Directive 2003/97/EC.  However, the requirements of 
>>this
>>Directive do not become compulsory for new cars until 26th January 2010.
>>Therefore, if the towing-mirror is already in use, or newly purchased 
>>now -
>>E marking is preferred (but not strictly required).
>>
>>If a NEW car is purchased after 26th January 2010, then 2003/97/EC or 
>>UNECE
>>Regulation 46 compliant caravan towing mirrors will be required for that
>>vehicle.  We assume that all caravan towing mirrors would comply with the
>>new requirements by that time.
>>
>>For those who want to be pedantic about the markings on the mirrors:
>>'e' in a rectangle signifies approval to the EC Directives; and
>>'E' in a circle signifies approval to the UNECE Regulation.
>>
>>Either of these markings is acceptable.
>>
>>I trust this helps.
>>
>>Kind Regards
>>
>>Brian
>>
>>Brian Greenway
>>Department for Transport
>>Transport Technology and Standards 8
>>Zone 2/05
>>Great Minster House
>>76 Marsham Street
>>London SW1P 4DR
>>
>>Tel:  020 7944 2115
>>Fax: 020 7944 2196
>>
>>
> Please send it to the CC
> -- 
> hugh
> Reply to address is valid at the time of posting
>
date: Sun, 11 May 2008 13:43:22 +0100   author:   Peter Balcombe

Re: Towing Mirrors   
Peter Balcombe wrote:
............

> Result the mirrors are years old,.claim they are 
> manufactured in the UK by Radyout (do they exist anymore?) but proudly bear 
> the E11 in a box.

Raydyot! No, they no longer exist under their own name.

They're now part of the American Truck-lite group who were probably only 
interested in Raydyot's commercial vehicle mirrors.

However, they're still offering 'towing' mirrors:
http://www.truck-lite.co.uk/truckliteuk/m_towing_uk.htm
date: Sun, 11 May 2008 15:35:56 +0100   author:   Dougal

Re: Towing Mirrors   
"Dougal"  wrote in message 
news:Oq2dnc-eqKPRmbrVnZ2dnUVZ8qGdnZ2d@eclipse.net.uk...
> Peter Balcombe wrote:
> ............
>
>> Result the mirrors are years old,.claim they are manufactured in the UK 
>> by Radyout (do they exist anymore?) but proudly bear the E11 in a box.
>
> Raydyot! No, they no longer exist under their own name.
>
> They're now part of the American Truck-lite group who were probably only 
> interested in Raydyot's commercial vehicle mirrors.
>
> However, they're still offering 'towing' mirrors:
> http://www.truck-lite.co.uk/truckliteuk/m_towing_uk.htm

That's interesting. My old pair look exactly like the M800s! They have 
worked fine on series of towcars.and the modern ones look rather cheaper 
than Milencos.

Peter

Peter
>
date: Sun, 11 May 2008 22:19:55 +0100   author:   Peter Balcombe

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