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| Bluest Member Since: 23 Apr 2016 Location: Lancashire Posts: 4216   
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It was discussed on here a long time ago when Brendan used to get very animated on this topic that it was not possible for a headlight to conform to DOT and E mark requirements at the same time, the requirements are different. Therefore anything marked as complying with both was likely to be dodgy. 2007 110 TDCi Station Wagon XS
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16th Oct 2022 8:06am |
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| kenzle8a Member Since: 12 Feb 2020 Location: None Posts: 1074 
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all one had to do is have a cursory search for 7 inch led headlights on Alibaba to realise that these are mostly not approved or those that are more expensive even from China and its harder to find the legitimate ones among the copy cats.
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16th Oct 2022 8:47am |
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| blackwolf Member Since: 03 Nov 2009 Location: South West England Posts: 17441 
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I think that one pertinent question here is whether SP 4x4 is aware that it is advertising and illustrating an apparently legal-to-use product but supplying something quite different. It is not presently illegal to own or sell unapproved headlights, but it would be to represent them falsely as approved units in order to sell them.
It would be legal also to fit them to a vehicle to which the approval regs did not apply (such as a SI) provided the beam pattern was compliant. |
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16th Oct 2022 10:38am |
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| OleDave Member Since: 19 Oct 2013 Location: CARDIFF Posts: 175 
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Hi blackwolf and everyone its been a while since I have had the pleasure of speaking to you all.
In b4 lamb absence i can confirm that neither his or the set I bought from SP carry the ECE mark and are marked as b4lamb advised as we both purchased them around the same time, as far as SP panels knowing whether these are UK legal or not is debatable, if you study their Web site the information supplied is very sparce other than they are E marked which one could interpret as possibly done on purpose or were they themselves duped ? My only experience after complaining to SP was they sent me some brief correspondence more or less advising i was confused as they were E marked! Since then I have not received any contact re my request to return them for refund, so you can look at that from any number of angles. I wasn't until b4lambs defender failed the mot on incorrect beam did I start an in depth look at my set and discovered they were identical, at the moment I am in studying various government documents relating to the guide for MOT testers, beam patterns and testing of asymrical and symmetrical headlights, I have in my possession beam patterns for both the above which were the latest changes to testing actioned in 2016 that following the change to the headlight testing procedure for HGV vehicles changed in 2015 due to unusually high failure rates which was later adopted in 2016 for private cars and light vehicles up to 850mm. I am also ploughing through slowly further gov information of which im sure you can imagine is vast and in many ways contradictory as I have a third beam pattern listed for British/American headlight testing which is a different beam pattern from the others. I will at some point post all the beam patterns along with the government guidelines when I think I have ploughed through it all to be fully confident that the info i post is correct, as im sure you will appreciate its a minefield, in addition im also hoping to dicuss this topic with a very good friend who is a current mot inspector, its just getting hold of him when he can afford the time as I have many many questions relating to beam testing Thats for the moment guys Regards to all Ole Dave |
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16th Oct 2022 3:28pm |
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| OleDave Member Since: 19 Oct 2013 Location: CARDIFF Posts: 175
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Hi guys and to be PC girls.
I said in my first post that as I progressed I would post the information, I can advise now that progression is causing brain fade as the more I study the more confusing it gets, how the individual inspectors see the regulations I think comes down to the individual inspector as vosa state a rule then in another document conradict it so im sure if you look long enough and hard enough a contradiction to the following could be found easily. OK first part. Vosa state that any modification of a halogen lamp to either HID or LED is an instant failure as the original halogen lens would not be compatible with either HID or LED light source, then in another document vosa states that its not up to the inspector to strip any component to verify it conforms, so the bottom line is as we all know the inspector only looks for the relevant beam pattern, if it matches it passes, but if you go that route be prepared for a failure. 2nd part. The E verification mark, it seems it matters not where the headlights were manufactured, the E mark is the country where the verification was carried out to ensure it conforms, E11 UK, E9 Spain, E1 Germany wether manufactured for LH or RH dip, they all should be working from the same page, so in fact verification for LH dip in Spain should conform. Part 3. Kick up. There are three beam patterns, asymmetrical, symmetrical and British/American patterns, I will post all three in due course, looking at the beam patterns, symmetrical does show a flat top to the pattern, asymmetrical which is the most commonly used these days does show a kick up on the left due to their shape, vosa does state and I quote :- Finally, you must still make sure that there is a kick up visible on the screen if its required, Remember that not all headlamps have kick ups, some have flat tops and some have deflectors fitted, if kick up is required it will only fail the test if it not visible on the screen :- unquote. Question here do all inspectors understand this ? as b4lambs inspector failed his LED lights on 4.1.2 beam pattern showing no kick up! The lens on his defender is symmetrical although LED and a quick test of mine which are identical show it having a flat top pattern. Well, thats it for me for the moment, going to have a few paracetamol and a lay down in a darkened room before I continue. Ole Dave [/b] |
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18th Oct 2022 1:08pm |
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| kenzle8a Member Since: 12 Feb 2020 Location: None Posts: 1074
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I didn't have any issues with symmetrical Truck Lites for my MOT.
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18th Oct 2022 1:35pm |
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| OleDave Member Since: 19 Oct 2013 Location: CARDIFF Posts: 175
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Hello lord haggis, lovely to hear from you, you don't mention what type they were, maybe you could offer a bit more of information on the type you fitted.
Ole Dave |
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18th Oct 2022 1:48pm |
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| blackwolf Member Since: 03 Nov 2009 Location: South West England Posts: 17441
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True, but of course only applicable in the case of light units designed and TA for an H4 bulb which have had the H4 bulb replaced with an LED or HID light sourse. If the MoT tester can see through the lens that the H4 bulb has been replaced with something else, or if it can be seen by other non-dismantling means (for example by seeing the connector on the back of the headlight when the bonnet is open) it should be a failure irrespective of the beam pattern. Inevitably there will some testers who are more observant, and some who are less observant (and maybe some who choose not to see). This however has no bearing on the case where the complete lamp has been replaced, rather than just the light source.
Also correct, but remember that a circle with an "E" followed by a number has, on its own, no meaning whatsoever. Only when combined with the rest of the obligatory markings does the "E"-mark indicate compliance. The remining markings indicate, inter alia, the type of light source, whether it is for LH or RH running, the approval number, the light type, the lens type, and other stuff I may have forgotten. A typical approval mark would read something like this: HCR PL 01 HCR PL A02 (E13) 17.5 13965 13964 --> HCR indicates a Class B headlight with both driving (R) and passing (C) beams which are illuminated simultaneously (i.e., on main beam both are lit) PL indicate a plastic (polycarbonate) lens The lights meet both the 01 and A02 series of amendments (E13) [noting that the brackets represent a circle] indicates that the approval was conducted in Luxembourg 17.5 is the peak luminous intensity The numbers beginning 13* are the approval numbers The arrow symbol indicates Left Hand traffic (i.e., UK, NZ, Australia, and the rest of civilised world) The markings above are actually taken from a Trucklite LED replacement light unit which is fully ECE compliant and legal. The bottom line is that if your replacement LED light units just have a mark reading DOT SAE (E-) where - is any number, and have no markings similar to the above, they are not legal anywhere in the world where UNECE type approval is mandatory irrespective of beam pattern. That is not to say yu won't get away with them, but they are not legal.
It is likely that you have access to info which hasn't previously been posted on here since you evidently know b4lamb, but the original post merely said that it had been failed on 4.1.2 c "beam image obviously incorrect". Whilst that may mean there is no kick-up where kick-up is expected, it could equally well be that the the beam is not flat, or has some other obvious defect. There are tales of cheap Chinesium LED headlights which have round beams (think torch beams), these would fail 4.1.2 c as well. So unless you have knowledge we don't, we cannot be sure that it is a lack of kick-up that resulted in the failure. If however your lights and his are identical, then it does suggest that the tester was expecting kick-up where there is none. Whatever the beam pattern, the sad fact remains that b4lamb, and I imagine, quite a few others, have been fooled into buying headlamps which, based on the information presented in this thread, cannot be legal to use on the road in the UK or anywhere in an ECE country. |
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18th Oct 2022 2:18pm |
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| OleDave Member Since: 19 Oct 2013 Location: CARDIFF Posts: 175
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Hi blackwolf its been a while since we spoke hope your OK,
i totally agree with your comments, there is however a vosa section which quite clearly says......No headlight Led or HID can be failed if manufactured as a unit and it meets the beam pattern required, vosa seems to be very vague on a lot of sections but if you look at the two beam patterns that I intend to post, the one beam, "Symmetrical" clearly shows a flat top and no kick up, my take on it and I stand corrected if not the case, that implys for that shape of lens its unlikely to produce kick up. Dave |
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18th Oct 2022 3:25pm |
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| kenzle8a Member Since: 12 Feb 2020 Location: None Posts: 1074
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Hi Dave, I’ve dug through my photos of them, I’ve found all the approval numbers stamped on them. They are E13 approved.  Click image to enlarge |
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18th Oct 2022 3:28pm |
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| blackwolf Member Since: 03 Nov 2009 Location: South West England Posts: 17441
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That is interesting, indicating that an LED or HID unit cannot be failed for not having the legally-required markings, and can only if it doesn't meet the beam requirements. However the MoT test does not check approval marks on anything, so perhaps not surprising.
Agree, noting that in the case of LED units it is not the lens which shapes the beam, it is either the shape of the projectors within the housing, or the shape of the reflector, or a combination of both. The SP lights appear to be copies in principle of the JW Speaker lights, and those do have a kick-up. However I do agree absolutely with you that if your lights and b4lamb's lights have a completely flat beam with no kick up then they should not fail the beam test. So either they do not (and we did ask to see a beam pattern on a wall from the lights but haven't yet), or the tester made a mistake. Without evidence of the beam shape it is not possible to know which it is. It also doesn't alter the fact that whilst unapproved LED units with a compliant beam pattern may pass the MoT beam test and hence the MoT test, they are still not legal to use on the road in the UK. I accept, however, that if the beam pattern is compliant you are unlikely to get stopped and it is unlikely that anyone will know. |
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18th Oct 2022 4:22pm |
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| B4Lamb Member Since: 21 Mar 2015 Location: Abergavenny, Wales Posts: 233  
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In answer to Blackwolf. Yes the MOT tester did say verbally that the LED lights had no kick up but maybe he just expects there to be one as the quaroptics standard fit Halogen units have a kick up but to be fair it may have been other aspects of the beam pattern that may have contributed or indeed overwhelmingly resulted in a fail. The tester can only use one of the three possible statements avsilbr yo choose in the test guidance.
Having said this I was not able to see what the tester was describing so I cannot say if it looked possible to adjust these hukeadlights to pass the beam pattern test. I read your statement that it is illegal to fit headlights that do not carry or can be traced back to the comprehensive standards you quote. I have not found where this requirement is stated. The MOT test only requires beam pattern tests it doesn't ask the inspector check details of the light unit fitted. To be fair this is the most important aspect as far as safety is concerned. If it is illegal to fit unqualified LED copy headlights then I would have expected this to be very prominent in the VOSA guidance but I have not seen it yet. "You are never to old to learn something new" |
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18th Oct 2022 5:46pm |
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| blackwolf Member Since: 03 Nov 2009 Location: South West England Posts: 17441
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It is (probably) not in VOSA guidance, in the same way as the Road Vehicles Lighting Regulations are not quoted in VOSA guidance - and as far as the MoT test is concerned, VOSA guidance only covers testable items, and as has been said many times before on this forum and elsewhere the MoT test is a roadworthiness test, not a conformity test. It is possible that you will find more information if VOSA has guidance for the SVA type approval test.
The regulations you want (perhaps "want" is the wrong word) is /ECE/324/Rev.2/Add.111/Rev.3 − E/ECE/TRANS/505/Rev.2/Add.111/Rev.3, Agreement Concerning the Adoption of Uniform Technical Prescriptions for Wheeled Vehicles, Equipment and Parts which can be fitted and/or be used on Wheeled Vehicles and the Conditions for Reciprocal Recognition of Approvals Granted on the Basis of these Prescriptions (Revision 2, including the amendments which entered into force on 16 October 1995) Addendum 111: Regulation No. 112 Revision 3 and it is available on line, and it is every bit as interesting as the title suggests. |
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18th Oct 2022 6:18pm |
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| OleDave Member Since: 19 Oct 2013 Location: CARDIFF Posts: 175
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Hi blackwolf it appears b4lamb has beaten me to the post!
I understand entirely where your coming from and I'm not able to offer criticism of any part, the one aspect I would comment on and im sure most of us on this forum are no different even possibly your goodself, we buy aftermarket parts, should we insist on those Goods having to carry an LR verification mark we would all be in trouble keeping our vehicles on the road, even though aftermarket parts do not carry an LR verification it does not follow that they are not fit for purpose, in some cases aftermarket parts can be a better option. In conclusion tonight blackwolf the goal in even starting this study is simply to achieve with the assistance of knowledgeable people like yourself and others on this wonderful forum, is, to get to the position where together we can come to a conclusion and if required offer valid advice on this subject, if we can achieve that we will have achieved something worthwhile. Ole Dave |
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18th Oct 2022 6:56pm |
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