Since the publication of the May Caravan Club article on Towing Mirrors, the Caravan Club have produced a revised article with differing information from that in the May article. This follows the receipt of further legal and professional advice, including revised advice from the Department for Transport (DfT,) since publication of the May article.
Before publication, Milenco Limited, Caravan Club and the Camping and Caravaning Club were advised e marking was a requirement from 12th December 2005. Since publication we have been advised the date is 26th of January 2010. To quote dft "Therefore, if a towing-mirror is already in use, or newly purchased now it should comply with the construction and testing requirements of the relevant legislation but ‘E’ or ‘e’ marking is not strictly required".
This revised information however, is in fact of little relevance to the content of the article unless non e marked mirrors comply with the relevant legislation. The Camping and Caravaning club has reported on their website that a journalist has tested a number of non e marked mirrors. 20 out of 20 were found to be dangerous and we therefore assume, did not comply with the relevant legislation. We have also tested a far larger number and have found the same result.
In respect of non e marked mirrors both clubs as a result are advising their members to ask to see a certificate of compliance from your supplier or manufacturer to show they meet the current requirements stated in C and U Regulations – European Directives 71/127/EEC or 2003/97/EC or United Nations (UNECE) Regulation 46.01 or 46.02.
With regards to the new regulations may we point out that the 26th of January 2010 is the absolute deadline for implementation of the 2003 standard. It is not the first day you must apply the new standard. All vehicle manufactures have already applied the new standards to their vehicles by 2006, as had we as a responsible manufacturer of mirrors, because it is an important safety improvement.
Our advice as a manufacturer in respect of our own products is mirrors approved to the old standard should not be used on post 2007 cars. Specifically the Milenco Universal mirror should not be used on car registered after the 26th of January 2007.
As a manufacturer we are concerned that mirrors made to the older standard could compromise in particular, pedestrian safety in the event of an accident if used on a post 2007 car therefore we do not recommend this.
Mirrors approved to the newer standard (Milenco Aero, Grand Aero & Safety) may be used on any car irrespective of age because they are made to the highest safety standard available.
In conclusion, we believe that the article published by the Caravan Club, has had a net positive effect on the safety of caravaning in 3 key areas.
- It has made caravanners aware of the dangers of towing without mirrors.
- It has made caravanners aware of the danger of illegal, non-conforming mirrors.
- It has made caravanners aware of new regulations which every car manufacture and responsible manufacturers of mirrors have already adopted for a number of years.
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