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ZeDefender



Member Since: 15 Sep 2011
Location: Munich
Posts: 4731

Germany 2011 Defender 110 Puma 2.4 SW Baltic Blue
Thanks for my certificate Tim Thumbs Up Tell someone you love them today because life is short.
But shout it at them in German because life is also terrifying and confusing...
Post #187790 24th Nov 2012 10:08am
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mobilecentre



Member Since: 05 Mar 2012
Location: Evesham
Posts: 645

United Kingdom 
ZeDefender wrote:
Thanks for my certificate Tim Thumbs Up


No problem at all - glad to help Bow down
Post #187791 24th Nov 2012 10:08am
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ericvv



Member Since: 02 Jun 2011
Location: Near the Jet d'Eau
Posts: 5816

Switzerland 2009 Defender 110 Puma 2.4 SVX Station Wagon Santorini Black
Just received copy by e-mail of that same certificate. Question is, it is certified by VCA, which is the UK vehicle approval authority.

Million dollar question.......... Does this approval only cover the UK, or is it automatically valid for all other EU countries like Germany, plus hopefully Switzerland too? You never actually own a Defender. You merely look after it for the next generation.
http://youtu.be/yVRlSsJwD0o
https://youtu.be/vmPr3oTHndg
https://www.youtube.com/watch?v=_GtzTT9Pdl0
https://www.youtube.com/watch?v=ABqKPz28e6A
https://www.youtube.com/watch?v=rLZ49Jce_n0
https://www.youtube.com/watch?v=XvAsz_ilQYU
https://www.youtube.com/watch?v=K8tMHiX9lSw
https://m.youtube.com/watch?v=dxwjPuHIV7I
https://vimeo.com/201482507
https://www.youtube.com/watch?v=ZSixqL0iyHw
Post #187796 24th Nov 2012 10:20am
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mobilecentre



Member Since: 05 Mar 2012
Location: Evesham
Posts: 645

United Kingdom 
ericvv wrote:
Just received copy by e-mail of that same certificate. Question is, it is certified by VCA, which is the UK vehicle approval authority.

Million dollar question.......... Does this approval only cover the UK, or is it automatically valid for all other EU countries like Germany, plus hopefully Switzerland too?


As per all the other posts it is not a UK approval but a European one......
Post #187797 24th Nov 2012 10:22am
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mobilecentre



Member Since: 05 Mar 2012
Location: Evesham
Posts: 645

United Kingdom 
ericvv wrote:
Just received copy by e-mail of that same certificate. Question is, it is certified by VCA, which is the UK vehicle approval authority.

Million dollar question.......... Does this approval only cover the UK, or is it automatically valid for all other EU countries like Germany, plus hopefully Switzerland too?


R112 is a European regulation so applies to all member states plus all others under the 1958 agreement as previously mentioned.

The actual testing of the lamp was carried out in the UK so has an E11 mark to denote this. The test was to ensure it met EUROPEAN approval.

For example if it was tested in Switzerland it would have an E14 mark.
Post #187798 24th Nov 2012 10:25am
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ericvv



Member Since: 02 Jun 2011
Location: Near the Jet d'Eau
Posts: 5816

Switzerland 2009 Defender 110 Puma 2.4 SVX Station Wagon Santorini Black
OK, finally there is light at the end of the tunnel, seems all clear now. Took a while. Good to have copy of this certificate.

I promise that I will not have similar questions about the LED number plate lamps which presume are in the post now Thumbs Up Rolling with laughter

Tks, Eric You never actually own a Defender. You merely look after it for the next generation.
http://youtu.be/yVRlSsJwD0o
https://youtu.be/vmPr3oTHndg
https://www.youtube.com/watch?v=_GtzTT9Pdl0
https://www.youtube.com/watch?v=ABqKPz28e6A
https://www.youtube.com/watch?v=rLZ49Jce_n0
https://www.youtube.com/watch?v=XvAsz_ilQYU
https://www.youtube.com/watch?v=K8tMHiX9lSw
https://m.youtube.com/watch?v=dxwjPuHIV7I
https://vimeo.com/201482507
https://www.youtube.com/watch?v=ZSixqL0iyHw
Post #187799 24th Nov 2012 10:32am
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SteveG



Member Since: 29 Nov 2011
Location: Norfolk
Posts: 659

2005 Defender 90 Td5 CSW Belize Green
mobilecentre wrote:

SteveG argues that the UK RVLR says you cannot use LED headlamps, IF his arguemnt was correct you would also not be able to use the original lamps because as far as the law is concerned they are the same becuase of the approval category.

By the way you already have your certficates Thumbs Up

Hi Tim

1989 legislation is the current legislation for vehicle lighting in UK - agreed?

1989 legislation only allows for filament headlamps to be used legally in UK - agreed?

Neither LED or HID are filament bulbs- agreed?

UK accepts European Type approval for new cars, thus allowing new cars to have LED & HID headlamps providing they meet Requirements - agreed?

An e approved headlamp units just means its met the requirements for that unit - agreed?

E type approvals are there to provide consistent manufacturing and in situ performance. They have nothing to do with the legislation of local vehicle lighting requirements. - agreed?

ECE R112 - is specification for a headlamp with asymmetrical beam with a halogen or led light source. - agreed?

Simply fittng an e approved headlamp unit does not make it legal. You have to fit in line with regional lighting legislation agreed?

Retrofitting LED & HID headlamps in UK is only allowed by DfT if using an e approved headlamp unit design for correct light source and fitted with self levelling and washers - agreed?

You said earlier you have a formal exception for the JW Speaker units from VOSA. Is this the case, or are you just saying that you have the ECE R112 certification. As this is not the same thing?

Thanks Steve
Post #187845 24th Nov 2012 2:44pm
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SteveG



Member Since: 29 Nov 2011
Location: Norfolk
Posts: 659

2005 Defender 90 Td5 CSW Belize Green
Anyone who wants to know testing requirements of ECE R112 and luminosity levels etc you can see requirements guidelines on a link here ....
http://www.jasic.org/j/07_wp29/pdf/28th_Expert_Meeting_j.pdf

With th caveat that you accept this could not be correct.

I see what you are saying Tim about ECE R112 is for halogen and LED, so if The headlamps meet the same requirement then they can be fitted like a halogen unit. However, this interpretation is different for a formal exemption and also differs from what the DfT are stating for retro fitting e approved LED headlamps.

Cheers

Steve
Post #187850 24th Nov 2012 3:00pm
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mobilecentre



Member Since: 05 Mar 2012
Location: Evesham
Posts: 645

United Kingdom 
SteveG wrote:
mobilecentre wrote:

SteveG argues that the UK RVLR says you cannot use LED headlamps, IF his arguemnt was correct you would also not be able to use the original lamps because as far as the law is concerned they are the same becuase of the approval category.

By the way you already have your certficates Thumbs Up

Hi Tim

1989 legislation is the current legislation for vehicle lighting in UK - agreed?

1989 legislation only allows for filament headlamps to be used legally in UK - agreed?

Neither LED or HID are filament bulbs- agreed?

UK accepts European Type approval for new cars, thus allowing new cars to have LED & HID headlamps providing they meet Requirements - agreed?

An e approved headlamp units just means its met the requirements for that unit - agreed?

E type approvals are there to provide consistent manufacturing and in situ performance. They have nothing to do with the legislation of local vehicle lighting requirements. - agreed?

ECE R112 - is specification for a headlamp with asymmetrical beam with a halogen or led light source. - agreed?

Simply fittng an e approved headlamp unit does not make it legal. You have to fit in line with regional lighting legislation agreed?

Retrofitting LED & HID headlamps in UK is only allowed by DfT if using an e approved headlamp unit design for correct light source and fitted with self levelling and washers - agreed?

You said earlier you have a formal exception for the JW Speaker units from VOSA. Is this the case, or are you just saying that you have the ECE R112 certification. As this is not the same thing?

Thanks Steve



As everyone else is getting bored lets simplify it.

Your statement was “LED headlamp units are just as illegal as HID lamps in UK if not fitted with self levelling and washers”

The justification you are using is a document advising (not legislative) about HID lamps and because you think that is what the DFT say.

As you use the word illegal then please show us either the specific statement from the DFT saying that LED headlamps are illegal without levelling and washers or the specific law preventing the use of LED headlamps within the aftermarket without the fitment of levelling or washing. I have already asked for this. Whistle
Post #187854 24th Nov 2012 3:11pm
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mobilecentre



Member Since: 05 Mar 2012
Location: Evesham
Posts: 645

United Kingdom 
SteveG wrote:
Anyone who wants to know testing requirements of ECE R112 and luminosity levels etc you can see requirements guidelines on a link here ....
http://www.jasic.org/j/07_wp29/pdf/28th_Expert_Meeting_j.pdf

With th caveat that you accept this could not be correct.

I see what you are saying Tim about ECE R112 is for halogen and LED, so if The headlamps meet the same requirement then they can be fitted like a halogen unit. However, this interpretation is different for a formal exemption and also differs from what the DfT are stating for retro fitting e approved LED headlamps.

Cheers

Steve


Please do not confuse people further by bringing Japan into this...,,
Post #187855 24th Nov 2012 3:12pm
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ZeDefender



Member Since: 15 Sep 2011
Location: Munich
Posts: 4731

Germany 2011 Defender 110 Puma 2.4 SW Baltic Blue
I am terrified to post this but is your issue that even though the headlamp meets all technical/safety regulations for being a headlamp, it doesn't necessarily mean you can stick it on any vehicle where you want?

This is true of my Hella driving lights that, even though they have an E approval, have to be fitted according to certain dimensions of the vehicle to be used in Germany.

As I understand it, the same standard 7" filament headlamps are found in a number of vehicles (the same in our Defender, 1974 Beetle and Harley Davidsons). Therefore, if the Speaker LED lamps are tested to comply (in comparison) with standard 7" filament lamps, then their E marking implies that they can be used as a universal direct replacement for any 7" filament lamp as long as nothing else changes (i.e. without self-leveling).

Sorry if that sounds daft Embarassed Tell someone you love them today because life is short.
But shout it at them in German because life is also terrifying and confusing...
Post #187856 24th Nov 2012 3:13pm
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mobilecentre



Member Since: 05 Mar 2012
Location: Evesham
Posts: 645

United Kingdom 
ZeDefender wrote:
I am terrified to post this but is your issue that even though the headlamp meets all technical/safety regulations for being a headlamp, it doesn't necessarily mean you can stick it on any vehicle where you want?

This is true of my Hella driving lights that have an E approval conditional upon them being fitted according to certain dimensions of the vehicle

As I understand it, standard 7" filament headlamps are found in a number of vehicles (the same in our Defender, 1974 Beetle and Harley Davidsons). They all have the same features. Therefore, if the Speaker LED lamps are tested to comply (in comparison) with standard 7" filament lamps, then their E marking implies that they can be used as a universal direct replacement.

Sorry if that sounds daft Embarassed


It is not daft as that is the main purpose of the RVLR 1989 to define the mounting and correct use, the part SteveG is missing is in order to mount the product on vehicles (IIRC) newer than 1979 it will need to be ECE approved which is what the RVLR are based around as the UK signed up in 1963 so this is what the RVLR 1989 is based upon - the European regs!

Take the Puma - LR homolgated that vehicle in 2007 with R112 approved headlamps so it met all current legislation. So today if you replace the lamp with another R112 unit and do not alter the height , width etc etc then there is no problem at all.
Post #187858 24th Nov 2012 3:26pm
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ZeDefender



Member Since: 15 Sep 2011
Location: Munich
Posts: 4731

Germany 2011 Defender 110 Puma 2.4 SW Baltic Blue
Thumbs Up Tell someone you love them today because life is short.
But shout it at them in German because life is also terrifying and confusing...
Post #187863 24th Nov 2012 3:33pm
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SteveG



Member Since: 29 Nov 2011
Location: Norfolk
Posts: 659

2005 Defender 90 Td5 CSW Belize Green
mobilecentre wrote:

As everyone else is getting bored lets simplify it.

Your statement was “LED headlamp units are just as illegal as HID lamps in UK if not fitted with self levelling and washers”

The justification you are using is a document advising (not legislative) about HID lamps and because you think that is what the DFT say.

As you use the word illegal then please show us either the specific statement from the DFT saying that LED headlamps are illegal without levelling and washers or the specific law preventing the use of LED headlamps within the aftermarket without the fitment of levelling or washing. I have already asked for this. Whistle


What rubbish Tim, I've given you the current legislation, and Ive always been clear about the context of the DfT exemption doc. Nice to see you attacking me! Totally unecessary as I've been quite clear throughout and consistent.

Before you claimed that you had special exemption, that no lounger seems to be the case. Now you are stating the basis is the fact that the JW Speaker has the same headlamp approval as halogen units do its ok as it's a direct swap.

So what you are saying is you don't know if they are legal or not. You THINK by using the same type of e approved headlamp people should be ok. This a bi different from before.

Current UK legislation says only filament headlamps are legal, so anything other than that retrofitted is illegal. DfT have said they will exempt HID & LED if fitted with self levelling and washers. That's clear, no ambiguity at all. Not sure why you dont understand this?

If you have a problem with this take it up with DfT, I'm just simply clarifying what's the current legal position.

Cheers

Steve
Post #187881 24th Nov 2012 4:57pm
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mobilecentre



Member Since: 05 Mar 2012
Location: Evesham
Posts: 645

United Kingdom 
Steve

My suggestion would be read your posts as your consistency is lacking in certain areas, as for rubbish I will leave those insults to you!

I never claimed special exemption – you assumed that is what JWS had and posted it in one of your assumptive responses Rolling with laughter

For the sake of clarity and consistency they are LEGAL which is what I have said since 2009 when we introduced them and did our due diligence Thumbs Up

I have never claimed any of what I have said is personal thoughts or assumptions – I will leave that to you.

As far as any “problem” with this it was not the DFT’s post helping everyone out by telling them their LED headlamps were illegal if not fitted with washing and levelling, it was yours Rolling with laughter

As I have said it’s very simple especially as you are just clarifying the situation – show us the specific legislation stating that retrofit JWS LED headlamps are illegal?

Still waiting……… Banging Head


Tim
Post #187933 24th Nov 2012 6:34pm
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