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Car Forum / Land Rover Cars / May 2008Towing Mirrors - most are now illegal!
All, Did you know that now all towing mirrors (by law) must be marked E11. Failure to have either a towing mirror on your car, or an "illegal" mirror (i.e. NOT marked E11) could lead to 3 points on your licence and a £60 fine. I didn't, its in the May issue of the Caravan Club Magazine (I checked it wasn't April 1st!) Cheers Peter > All, > [quoted text clipped - 10 lines] > > Peter Surely this only applies to vehicles produced from the date the legistlation came in to power? I didn't know in fairness. Don't use them on the 110 or the RR, Used to onthe old RR and Disco. Lee >> All, >> [quoted text clipped - 18 lines] > > Lee Lee, This is all news to me as well! Statutory Instrument 3165/2005 says that from 12 December 2005 it is a legal requirement that you use type approved mirrors (E-marked) on both sides of the vehicle in the UK. Well, the law also states that you must be able to clearly see down both sides of the caravan and 4m either side, at a distance of 20m behind the caravan. (Basically only the widest of cars towing the narrowest of caravans wont need mirrors). Note, CE marks DON'T ally, it must be "E" marked. Finally, it is not illegal to sell non "E" marked mirrors, just to use them. Looking at the legislation (and I'm no expert) it would seem that us car drivers have been caught up in legislation for larger vehicles. The website is at http://www.opsi.gov.uk/si/si200531.htm Does anybody else have any views? Cheers Peter >>> All, >>> [quoted text clipped - 47 lines] > > Peter I think that we should all take a deep breath and go away and read the paperwork. Much of what I have seen/heard so far does not tally with what I read in the regulations/directives. Most, if not all, existing legal installations will remain so from what I have seen so far. Does anyone know the source of the 4m to the side 20m back view requirement? I haven't found it yet. >>> All, >>> [quoted text clipped - 42 lines] > >Does anybody else have any views? It's in C&U but it's one of the more obscure bits. Seems to be a date of 26th January 2010, after which you need mirrors thusly: Mirrors or other devices for indirect vision complying with Annex III to Community Directive 2003/97 or 2005/27 or paragraph 15 of ECE Regulation 46.02. mirrors should comply with: Paragraph 6 of Annex I and Annex II to Community Directive 2003/97 or 2005/27 or paragraphs 4, 5 and 6.1 of ECE Regulation 46.02. Prior to that and after 1st June 1978 (or 10th July if it's a transit), you need: (i) At least 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. mirrors should comply with: Item 2 of Annex I to Community Directive 71/127 or 79/795 or Annex II to Community Directive 86/562 or 88/321 or paragraphs 4 to 8 of ECE Regulation 46.01 and paragraphs (2) and (4) of this regulation. But that's a very small excerpt. Different rules for buses and commercials, and for various other things, and different dates too.  SignatureAustin Shackles. www.ddol-las.net my opinions are just that Travel The Galaxy! Meet Fascinating Life Forms... ------------------------------------------------\ >> http://www.schlockmercenary.com/ << \ ...and Kill them. a webcartoon by Howard Tayler; I like it, maybe you will too! > Prior to that and after 1st June 1978 (or 10th July if it's a transit), you > need: [quoted text clipped - 9 lines] > Community Directive 86/562 or 88/321 or paragraphs 4 to 8 of ECE Regulation > 46.01 and paragraphs (2) and (4) of this regulation. ... and there's a pre-1st Jun 1978 get out for dual-purpose vehicles (remember them?) from any regulatory requirement for the mirrors themselves other than that any interior mirror should not have edges likely to injure if struck. "> mirrors should comply with: > Paragraph 6 of Annex I and Annex II to Community Directive 2003/97 or > 2005/27 or paragraphs 4, 5 and 6.1 of ECE Regulation 46.02. Interesting the use of the wording "should comply"; normally in legislation "should" indicates a recommendation not a compulsion, "shall" or "must" are normally used to indicate that something is a requirement. Regards Jeff >"> mirrors should comply with: >> Paragraph 6 of Annex I and Annex II to Community Directive 2003/97 or [quoted text clipped - 3 lines] >"should" indicates a recommendation not a compulsion, "shall" or "must" are >normally used to indicate that something is a requirement. I think it might be, hangon... that was my wording, not the legislation. The table heading says: "4 Requirements to be complied with by any mirrors fitted" BTW, I can't see an exemption for pre-78 vehicles. They're item 9 in the table: "A wheeled motor vehicle, not in items 1 to 7, first used before 1st June 1978 (or in the case of a Ford Transit motor car, 10th July 1978) and a track-laying motor vehicle which is not an agricultural motor vehicle first used on or after 1st January 1958, which in either case is :- (a) a bus; (b) a dual-purpose vehicle; or (c) a goods vehicle." and they need mirrors: "At least one exterior mirror fitted on the offside of the vehicle and either one interior mirror or one exterior mirror fitted on the near-side of the vehicle." but no requirements for the mirrors themselves, other than the general para. 3, which is: "(3) Save as provided in paragraph (5), in the case of a wheeled motor vehicle described in item 1, 2, 10 or 11 of the Table which is first used on or after 1st April 1969 the edges of any interior mirror shall be surrounded by some material such as will render it unlikely that severe cuts would be caused if the mirror or that material were struck by any occupant of the vehicle." Para 5 lists the various approved mirror regulations. Item 10 is "everything else", and has to have at least 1 mirror, internal or external. SignatureAustin Shackles. www.ddol-las.net my opinions are just that Travel The Galaxy! Meet Fascinating Life Forms... ------------------------------------------------\ >> http://www.schlockmercenary.com/ << \ ...and Kill them. a webcartoon by Howard Tayler; I like it, maybe you will too! > BTW, I can't see an exemption for pre-78 vehicles. They're item 9 in the > table: I think you mean Item 10 > "A wheeled motor vehicle, not in items 1 to 7, first used before 1st June > 1978 (or in the case of a Ford Transit motor car, 10th July 1978) and a [quoted text clipped - 12 lines] > but no requirements for the mirrors themselves, other than the general para. > 3, which is: > "(3) Save as provided in paragraph (5), in the case of a wheeled motor > vehicle described in item 1, 2, 10 or 11 of the Table which is first used on > or after 1st April 1969 the edges of any interior mirror shall be surrounded > by some material such as will render it unlikely that severe cuts would be > caused if the mirror or that material were struck by any occupant of the > vehicle." > Para 5 lists the various approved mirror regulations. Para 5 lists alternatives to paras 1-4 i.e. if not using the table. > Item 10 is "everything else", and has to have at least 1 mirror, internal or > external. I think you mean Item 11 I think this was my comment that you're querying .... You're correct that there is no exemption from the use of mirrors. I didn't suggest otherwise! What I was trying to point out was that in this case the mirrors themselves did not have to meet any regulatory requirements - Table, Column 4: Requirements to be complied with by any mirrors fitted. For Item 10 - None etc. as you quoted above. - i.e. no E-mark, BS Kitemark etc.. So your dual-purpose pre-1st June 1978 Land Rover can use bits of polished metal, glass with kitchen foil stuck on the back. A "mirror" for the purpose of this regulation means any device with a reflecting surface (Para 7). But, oops, I did miss seeing the post-1st April 1969 date for the interior mirror with injury-free surround! .... Or that's how I read it. Nothing personal - just having fun nit-picking! But it just goes to illustrate what a mess our laws have become. >> BTW, I can't see an exemption for pre-78 vehicles. They're item 9 in the >> table: >I think you mean Item 10 yeah, I do. dunno how that happened. >Nothing personal - just having fun nit-picking! But it just goes to >illustrate what a mess our laws have become. SignatureAustin Shackles. www.ddol-las.net my opinions are just that Travel The Galaxy! Meet Fascinating Life Forms... ------------------------------------------------\ >> http://www.schlockmercenary.com/ << \ ...and Kill them. a webcartoon by Howard Tayler; I like it, maybe you will too! >>> BTW, I can't see an exemption for pre-78 vehicles. They're item 9 >>> in the table: [quoted text clipped - 4 lines] >> Nothing personal - just having fun nit-picking! But it just goes to >> illustrate what a mess our laws have become. Upshot to me, let the c.nts pull me & prove it. SignatureNige, talking utter shite since 1967. Focus ST3 Discovery 3 XS BMW K1200S NIGE#1 >>>> BTW, I can't see an exemption for pre-78 vehicles. They're item 9 >>>> in the table: [quoted text clipped - 6 lines] > >Upshot to me, let the c.nts pull me & prove it. Now now, that's no way to refer to our esteemed police force... SignatureAustin Shackles. www.ddol-las.net my opinions are just that Travel The Galaxy! Meet Fascinating Life Forms... ------------------------------------------------\ >> http://www.schlockmercenary.com/ << \ ...and Kill them. a webcartoon by Howard Tayler; I like it, maybe you will too! >>>>> BTW, I can't see an exemption for pre-78 vehicles. They're item 9 >>>>> in the table: [quoted text clipped - 8 lines] > > Now now, that's no way to refer to our esteemed police force... I didn't mean them inparticular, just any f.cker that gives a toss about towing mirrors would be low on my Christmas list. SignatureNige, talking utter shite since 1967. Focus ST3 Discovery 3 XS BMW K1200S NIGE#1 >>>>>> BTW, I can't see an exemption for pre-78 vehicles. They're item 9 >>>>>> in the table: [quoted text clipped - 11 lines] > I didn't mean them inparticular, just any f.cker that gives a toss about > towing mirrors would be low on my Christmas list. I'll bring my collection to ...... what? what? ;-) Lee D >>>>>>> BTW, I can't see an exemption for pre-78 vehicles. They're item 9 >>>>>>> in the table: [quoted text clipped - 27 lines] > >Lee D The following was posted on uk.rec.caravanning 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 Signaturehugh Reply to address is valid at the time of posting > 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. I've half been following this thread but all I've seen so far is in reference to towing a caravan. Do these regulations (old, new, soon to be, pie in the sky) apply to towing anything or just specifically to a caravan. If just to a "caravan" what is the defintion of a "caravan". When I tow my trailer I can't see it in any mirror unless going round a fairly tight corner. SignatureCheers Dave. >>The requirements for caravan towing mirrors follow the vehicle mirror >>requirements as defined in Regulation 33 of the Road Vehicles [quoted text clipped - 7 lines] > When I tow my trailer I can't see it in any mirror unless going round a > fairly tight corner. All the regulations are about the mirror of the towing vehicle with or without a trailer attached. Mirrors for use with trailers are considered to be vehicle mirrors and subject to the same requirements. A caravan is a trailer: the word 'caravan' is not in the regulations. There is nothing about what is seen in the mirror other than when the combination is in a straight line. You've got a little trailer! The rules for the interior mirror don't require you to see anything foward of a point on the ground 60m behind the driver's eye (ocular points). > All the regulations are about the mirror of the towing vehicle with or > without a trailer attached. Mirrors for use with trailers are considered > to be vehicle mirrors and subject to the same requirements. A caravan is > a trailer: the word 'caravan' is not in the regulations. Ah right so anything towed. > There is nothing about what is seen in the mirror other than when the > combination is in a straight line. I can't see anything of my trailer when in a straight line. Not even the wheel arches. So on a 2001 Disco should I have "towing mirrors" fitted when I have the trailer hitched? The door mirrors have no markings. > You've got a little trailer! Well it's a "medium" open box about 6' long 4' wide, 2' deep. The overall width means it has to have a full light board with two fog lights. > The rules for the interior mirror don't require you to see anything > foward of a point on the ground 60m behind the driver's eye (ocular > points). That explains what entire family saloons can disappear into the blind "spot" behind a Disco. I don't think many people driving family saloons realise that. SignatureCheers Dave. >>All the regulations are about the mirror of the towing vehicle with or >>without a trailer attached. Mirrors for use with trailers are considered [quoted text clipped - 9 lines] > wheel arches. So on a 2001 Disco should I have "towing mirrors" fitted > when I have the trailer hitched? There's no reason to do so. The view requirements for the normal exterior mirrors do not cover anything inboard of a plane parallel to the vertical longitudinal median plane and through the extreme outer point of the vehicle (vehicle/trailer combination). There's obviously nothing stopping you installing something that allows you to see inboard of that plane and possibly revealing your trailer but I don't see anything that forces you to do so. There's a limit to how far your mirror can project outboard beyond the widest point too, which might scupper the idea for your trailer anyway. > The door mirrors have no markings. Look more closely at your standard mirrors. The markings are not on the glass, they're moulded into the plastic housing. LR have been using class III mirrors since at least the late RRCs - you'll have them, too. >>You've got a little trailer! > [quoted text clipped - 8 lines] > "spot" behind a Disco. I don't think many people driving family saloons > realise that. Hit the brakes very hard - they'll soon learn that they can't be seen! Did that once in the fog with a 'Roller' that wanted to be in the back of my ex-mil Series IIa (bumperettes, NATO hook etc.) - very effective it was, too. > There's no reason to do so. The view requirements for the normal > exterior mirrors do not cover anything inboard of a plane parallel to > the vertical longitudinal median plane and through the extreme outer > point of the vehicle (vehicle/trailer combination). Fine, I'll go back to sleep. >> The door mirrors have no markings. > > Look more closely at your standard mirrors. The markings are not on the > glass, they're moulded into the plastic housing. Yes E11 in boxes or circles. That strikes me as a bit stupid, the plastic housing is just that a housing who is to say the functional bit (the mirror) is still to the OEM spec that met the E marking? SignatureCheers Dave. >>There's no reason to do so. The view requirements for the normal >>exterior mirrors do not cover anything inboard of a plane parallel to [quoted text clipped - 11 lines] > housing is just that a housing who is to say the functional bit (the > mirror) is still to the OEM spec that met the E marking? The e11 or E11 in boxes are the E-marks. You should also see a II (class II) or III (class III) outside but near the boxes. Yes, the mirror part does seem to hang in there without any tie to the housing. I also thought that strange. The housing, of course, has requirements to meet, too! And there's one thing that I have yet to work out is how an add-on 'towing' mirror can be given a 'class' as the tests specify the position of the mirror. In many respects most of the dimensions relate to the driver's seat and it's position in a specified vehicle. If the vehicle is unknown - as befits an add-on - it all gets very grey. Some day I might try to understand it. >Yes, the mirror part does seem to hang in there without any tie to the >housing. I also thought that strange. The housing, of course, has >requirements to meet, too! the housing is what holds the mirror to the vehicle, hopefully steady enough that it's of some use. SignatureAustin Shackles. www.ddol-las.net my opinions are just that Travel The Galaxy! Meet Fascinating Life Forms... ------------------------------------------------\ >> http://www.schlockmercenary.com/ << \ ...and Kill them. a webcartoon by Howard Tayler; I like it, maybe you will too! >>>There's no reason to do so. The view requirements for the normal >>>exterior mirrors do not cover anything inboard of a plane parallel to [quoted text clipped - 24 lines] > >Some day I might try to understand it. Well if you succeed come and explain it to the rest of us. Signaturehugh Reply to address is valid at the time of posting >>> All, >>> [quoted text clipped - 26 lines] > legal requirement that you use type approved mirrors (E-marked) on both > sides of the vehicle in the UK. The Regulation came into force on 12 December 2005 but the effective dates are different. The one that we're most likely to meet is for vehicles first used from 27 January 2010. > Note, CE marks DON'T ally, it must be "E" marked. Yes, they're diffferent things. > Cheers > > Peter >> All, >> [quoted text clipped - 18 lines] > >Lee The CC magazine article had a cop out (if you'll excuse the expression) Their own legal department had found it too hard and difficult - so they'd asked a mirror manufacturer. Where else would you go to get a fair unbiassed rational explanation of the need or otherwise to go out and spend lots of your hard earned money buying their product? Signaturehugh Reply to address is valid at the time of posting > In message <67pbfeF2q4ra...@mid.individual.net>, Lee_D > <newsgroupsNOS...@NOSPAMlrproject.com> writes [quoted text clipped - 32 lines] > > - Show quoted text - Yes, I noticed that and I plan to write to the Caravan Club and ask: 1. Why didn't they see it (the legislation) coming; and 2. Why are their legal department not competent to work it out so we have the gen from (as you correctly say) a potentially biased seller. Cheers Peter >>> All, >>> [quoted text clipped - 23 lines] > unbiassed rational explanation of the need or otherwise to go out and > spend lots of your hard earned money buying their product? I was being idle and not posting but a pure coincidence that a certain mirror manufacturer has launched an EII marked mirror and a misleading advertising campaign plus a series of ' press releases' ( yeh my arse they are) to go with it then ? Derek > All, > > Did you know that now all towing mirrors (by law) must be marked E11. E-marked if appropriate but not necessarily E11 which is for stuff homologated in the UK. Other countries use numbers other than 11. > Cheers > > Peter I don't use them .... Discovery and Range Rover are wide enough to see down the sides, and I can see through the rear of the van with my rear view mirror... SignatureNeil >I don't use them .... Discovery and Range Rover are wide enough to see down >the sides, and I can see through the rear of the van with my rear view >mirror... Checked my Defender (98) mirrors and they are stamped E2. Signaturehugh Reply to address is valid at the time of posting >All, > [quoted text clipped - 10 lines] > >Peter Peter, Don't believe everything you read in the Caravan Club magazine :o( The information for the article was supplied by the mirror manufacturer Milenco! Guess who is the only supplier currently making mirrors bearing the marks they say are a legal requirement? Here is copied the text of an email reply from the Department for Transport, to a caravan accessories retailer following a request for clarification of that CC article. "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 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." (Reply via NG please) >Peter, > [quoted text clipped - 32 lines] > >I trust this helps." yep. It underlines what I'd already deduced from reading the legislation - there's a change in 2010 but it's almost certainly not retrospective. Has anyone written a rude letter to the CC magazine for this? I'd be inclined to, if I were a member. They should check their facts a bit more carefully and consider the source of such articles. SignatureAustin Shackles. www.ddol-las.net my opinions are just that Travel The Galaxy! Meet Fascinating Life Forms... ------------------------------------------------\ >> http://www.schlockmercenary.com/ << \ ...and Kill them. a webcartoon by Howard Tayler; I like it, maybe you will too! On 7 May, 07:37, Austin Shackles <austinDITCHTHISFORBETTERRESU...@ddol- las.net> wrote: > >Peter, > [quoted text clipped - 47 lines] > > - Show quoted text - Yes, I plan to. As a CC member I was disappointed and disgusted (I'd said that in an earlier e-mail in this thread) that their own "Legal Department" found it too tricky to deal with and that they had to publish an article that was out and out to sell mirrors (and frighten the readers into doing so). Cheers Peter In message <1990b804-e225-4b02-8f49-ea22a07d5d46@34g2000hsf.googlegroups.com>, puffernutter <peter@puffer-nutter.co.uk> writes >On 7 May, 07:37, Austin Shackles <austinDITCHTHISFORBETTERRESU...@ddol- >las.net> wrote: [quoted text clipped - 61 lines] > >Peter Me too. They're just the same with LPG and Calor. Right up their arses they are. Signaturehugh Reply to address is valid at the time of posting > In message >>Yes, I plan to. As a CC member I was disappointed and disgusted (I'd >>said that in an earlier e-mail in this thread) that their own "Legal [quoted text clipped - 6 lines] >>Peter > Me too. They're just the same with LPG and Calor. Right up their arses they are. Think of all the revenue they get from THOSE TWO ADVERTISERS Me I'm not Cynical !! back to lurking / learning mode now DieSea
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