ken wrote:

Lee I'm afraid he's wrong Led head lamps are fine the do not need self level or washers

Been debated many many times I'm on the iPad so unable to post the C&U's that cover this topic might try at 04:30 if no one else has done by then

I'm afraid you are Ken. Current UK lighting law is 1989 vehicle lighting regs which explicitly states what is legal fitment. Neither HID or LED are mentioned. New cars are exempt from this if they meet European Type Approval.

Dft makes an exception for high intensity lights which includes LEDs if they are mounted in a EU type approved headlamp assembly and fitted with self levelling and headlamp washers.

Not trying to obstructive, people can do what they want, I just came across this statement when searching on here and thought it was worth correcting so that people knew what was right. Nothing more than than that. Doesn't matter whether its my first post or 1001 post.

Cheers

Steve

SteveG wrote:

ken wrote:

Lee I'm afraid he's wrong Led head lamps are fine the do not need self level or washers

Been debated many many times I'm on the iPad so unable to post the C&U's that cover this topic might try at 04:30 if no one else has done by then

I'm afraid you are Ken. Current UK lighting law is 1989 vehicle lighting regs which explicitly states what is legal fitment. Neither HID or LED are mentioned. New cars are exempt from this if they meet European Type Approval.

Dft makes an exception for high intensity lights which includes LEDs if they are mounted in a EU type approved headlamp assembly and fitted with self levelling and headlamp washers.

Not trying to obstructive, people can do what they want, I just came across this statement when searching on here and thought it was worth correcting so that people knew what was right. Nothing more than than that. Doesn't matter whether its my first post or 1001 post.

Cheers

Steve

mobilecentre wrote:

Welcome to Def2

Certainly feeling it, with quotes like this!

Hi Tim

I was posting while your post was added. I'm simply stating current 'official' stance from DfT. if Bristol has approved then they need to get formal statement issued by DfT, as until they do then previous still stands. So do you have written approval from DfT that has been published on here or elsewhere? Just asking as it wold be useful to have this, again not trying to be obstructive.

Cheers

Steve

SteveG wrote:

mobilecentre wrote:

Welcome to Def2

Certainly feeling it, with quotes like this!

Hi Tim

I was posting while your post was added. I'm simply stating current 'official' stance from DfT. if Bristol has approved then they need to get formal statement issued by DfT, as until they do then previous still stands. So do you have written approval from DfT that has been published on here or elsewhere? Just asking as it wold be useful to have this, again not trying to be obstructive.

Cheers

Steve

adafish wrote:

LandRoverAnorak wrote:

Melbourne isn't in the EU...

.............
they have EMU markings....

Thanks, made me laugh that  

mobilecentre wrote:

DFT makes no such exception, there may be a poorly worded statement on their website which does not offer any clarification of the law.

Putting all of that to one side if you have a look at a JWS headlight it is approved under R112 which covers filament lamps so in essence ANYWHERE you can use an E approved filament headlight with R112 (Which is all Defenders) you can use the Speaker lamp. Using your point about 1989 Vehicle Lighting means through your own “facts” posted the lamps are perfectly legal as they are approved as a lamp commercially used for the last 30 years…

mobilecentre wrote:

Your previous also cannot stand as the LED headlights we sell are approved in essence as filament lamps. So if you are right that means every Defender made since the 1970's also has illegal headlamps as they carry the SAME approval. It also means based upon what you are saying

Audi
VW
Lexus
Bugatti
Aston Martin
Jaguar
BMW
Rolls Royce
McLaren
John Deere
Harley Davidson

Who all run LED headlamps are also illegal?

I appreciate that you may feel based upon what you have read you are right, but the better way in my opinion would have been to ask the question are LED headlamps legal?

SteveG wrote:

Here's the exception wording... http://assets.dft.gov.uk/publications/dft-...dlamps.pdf

Seems quite clear and doesn't appear poorly worded to me.

As per your last statement, as I assume you are aware, an LED isn't a filament lamp and is therefore not legal under the 1989 regs, so no matter what e approved enclosure it won't be legal unless its retro fitted in a way that complies with Dft exception.

Cheers

Steve

SteveG wrote:

mobilecentre wrote:

Your previous also cannot stand as the LED headlights we sell are approved in essence as filament lamps. So if you are right that means every Defender made since the 1970's also has illegal headlamps as they carry the SAME approval. It also means based upon what you are saying

Audi
VW
Lexus
Bugatti
Aston Martin
Jaguar
BMW
Rolls Royce
McLaren
John Deere
Harley Davidson

Who all run LED headlamps are also illegal?

I appreciate that you may feel based upon what you have read you are right, but the better way in my opinion would have been to ask the question are LED headlamps legal?

No this worries me. I had assumed by your previous post you knew this intimately and knew something I didn't know. Then you make statements like this about these manufacturers having cars with LED Headlamps

As per above, the DfT's accepts EU Type Approval for new cars, so any car that conforms to EU type approval is ok to run HiD and LED and hence there are tons that are.

This has nothing to do with retro fitting which is what I'm talking about.

So as this has been debated tons of time before, where is the proof that its legal to retro fit them without meeting DfT requirements? Surely you can point me to it.

No axe to grind, just looking for facts that prove they are legal to fit, as I'd personally like to have this before fitting them.

Cheers

Steve

No need to worry - It is part of my job to understand the compliance aspect when it comes to LED when working with some of the companies above on both OEM & Aftermarket programmes.

You also never even mentioned retrofit in your first post however you will notice I did.

Then there is the discussion about retrofitting HID using an approved lamp in the aftermarket where you do not need levelling or washing

The proof is stamped on every single LED headlamp we sell - as the law demands that

SteveG wrote:

Hi Tim

Just to be clear, 1989 legislation is the law, this does not allow you to legally have HID or LED headlamps. No ambiguity there.

The above DfT doc provides guidance on their exception to this. It does not have to be legislation.

So legally you can only have HID and LED headlamps on new european type approved vehicles. To retrofit you need to follow exception guidance which means fitting e approved headlamp assembly with self levelling and washers. Anything else is illegal under current UK law.

There's no ambiguity here. So until DfT change their stance that's the situation.

Cheers

Steve

Just to be clear Steve - you are wrong about the application.

As previously offered you do not have to take my word for it - just speak to the people at the VCA or indeed VOSA who will MOT the vehicle with them fitted who of course according to your version will be failing all the cars with them fitted as an aftermarket accessory. On that one I suggest you speak to Andrew Cattell who is the Vehicle Standards Manager who I have worked with in the past with regard to the new MOT testing guidelines and the impact of LED and the requirement NOT to have washing and levelling and the subsequent redactions printed in various Land Rover magazines who said exactly the same thing you are saying then had to print an apology. I suppose their legal people were also wrong when they printed the apology for getting their facts wrong in exactly the same way as you and funnily enough one even used the same document that you have quoted

The 1989 RVLR may be the law with regard to placement and operation however not to the construction of the lamps which it hands over to the UNECE so in order to comply with the 1989 RVLR you would need an ECE approved lamp fitted to say a 1996 Defender. This vehicle still complies with the RVLR if you do not alter the mounting height / position and fit a correctly ECE approved LED headlamp. As the RVLR governs position and operation.

The 7” LED headlamps from JWS have a luminous flux below the level required for washing or levelling which is why they are approved under R112 which governs filament lamps (and LEDs even you say it does not even though it is clearly printed on the first page that it does ) So to recap even under the 1989 regs on their own there is no requirement for washing and levelling as the luminous flux is not great enough.

All you have offered is your FYI, there is no proof at all of what you say. The document you based it on does not even mention LEDs, you keep referring to the 1989 regs however do not seem to be aware about the 1958 agreement which the UK agreed to abide by in 1963 which covered the harmonisation of vehicles and components through a Europe wide type approval process denoted by an ECE marking. There are no restrictions on this process for aftermarket or OEM hence why LR can fit a light from Hella which was produced for the aftermarket and type approve their vehicle. Then twenty years later a dealer can buy one from Wipac and fit that.

Just as we sell product to vehicle manufacturers for new build or say via the Harley aftermarket to fit into a 30 year old bike. Both use the same product and both applications are legal.

The point of ECE markings is to show that if fits a set of pre-determined standards required at point of production of the vehicle and then if that component needs to be changed at a later point through damage, upgrade whatever your ensure that the product meets or exceeds the original requirement in terms of safety or performance.

I have worked on a refurbishment programme this year where we needed to complete all our due diligence for compliance using the 7” LED headlight as a retrofit from sealed beam so have done exactly what you say cannot be done and they have their own legislation compliance team!

Suffice to say if anyone is still awake after reading this and wants to see the ECE marking then feel free to contact me or any other member with the lamps fitted and they can show you a picture, if you want to see the approval certificate then PM me. If you want to speak to the VCA or VOSA let me know and I will happily introduce you. If you need proof they pass an MOT then drop me a line as I have plenty of customers going through that process and TUV etc etc

I agree there is no ambiguity - what you are saying is unfounded and misleading to this forum,

I look forward to your written proof from the DFT stating replacement LED headlamps from JWS are illegal when retrofitted even if suitably E marked. I hope we all do not have to wait long as their stance is so strong.

Regards


Tim

ken wrote:

Thanks Tim that saved me a lot of typing

I hope you read all of it