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 Topic: mirrors
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02/5/2008 at 10:30am
Location: Cornwall
Outfit: Autotrail Scout
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Sorry to post thrice in a row in the same thread.
I just got off the phone to the Caravan Club. They thanked me for offering my information but say they had already become aware through other channels of the possibility of significant errors in the information that Milenco provided that formed the basis of their article in this month's magazine. They're reviewing the situation and will probably publish a correction next month.
In the meantime, I can now categorically state that:- There are one or more routes to compliance with the current requirements that do not require e-marking. Thus, although e-marking is preferred, it is not strictly required, and those unmarked mirrors could well be legal.
- Both forms of e-marking - a lower case "e" in a rectangle and an upper-case "E" in a circle - are acceptable for cars first used before the 26th January 2010. The difference is that (assuming Italian made mirrors) "[e3]" signifies compliance with an EC Directive while "(E3)" signifies compliance with ECE Regulation 46.
- For cars first used on or after 26th January 2010, mirrors must comply with 2003/97/EEC or ECE Reg 46. You may not use unmarked mirrors or mirrors that comply with the older Directives on 2010 or later cars.
I am also convinced that only one towing mirror is required for current outfits that have adequate view to the rear via an interior device for indirect vision (e.g. an interior mirror or a rear-view camera). However, two mirrors will be required for cars first used on or after the 2010 cut-off date.
Also, the requirement to be able to see down both sides and 4m of the road either side at 20m behind the outfit seems to be introduced with ECE Reg 46, which only becomes mandatory in 2010. Prior to that, the only regulations I can find are the Motor Vehicles (Approval) Regulations 2001, which describes field of view with reference to marks and poles laid out according to an annexed diagram, and seems to apply only at the time of testing for approval.
HTH,
Geoff
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