Ok, so I decided to write to the DVSA concerning the oft asked topic about Xenon upgrades and the like on cars that were not fitted with them originally.
After a few weeks, I had a response back and this has more or less confirmed that there is a distinction between the MOT side and the Legal road use side.
As far as the MOT goes: Headlamp cleaning systems are only tested where fitted on vehicles first used on or after 1 September 2009. They also cannot determine the luminous intensity of headlamps, so would not be able to determine if these are over 2000 lumens. It is worth pointing out that the requirement for headlamp levelling and wash for HID headlamps only applies if their luminous intensity exceeds 2000 lumens.
However, as far as road legal use is concerned, it is a different matter:
I put a specific scenario to the DVSA:
- A person has a standard vehicle fitted with standard halogen headlamps.
- The individual replaces the complete headlamp unit (not a bulb conversion) with an original Manufacturer part Xenon headlamp version. They may make some wiring adaptations to fit it for example.
- The individual does not fit a headlamp wash system
- The individual does not fit a levelling system
To quote the summary from the response I had in relation to this scenario:
DVSA August 2018
So to summarise; in relation to your scenario of a standard vehicle fitted with standard halogen headlamps that has had the complete headlamp unit (not a bulb conversion) with an original Manufacturer part Xenon headlamp version with no headlamp wash system or automatic levelling system – this vehicle would be not meet the legal requirements for HID headlamps (assuming the unit was more than 2000 lumens), but would pass the MOT test.
The relevant extract from the guidance on aftermarket HID Headlamps follows; the full link is:
https://www.gov.uk/government/publicati ... -headlamps
ECE Regulation 48
ECE Regulation 45
3. HID headlamp unit requirements
Therefore a HID headlamp unit sold in the aftermarket should:
- be type approved to ECE Regulation 98 as a component
- when fitted to the vehicle should enable ECE Regulation 48 to be complied with (although no government inspection will take place)
- comply with RVLR as far as “use” is concerned
In practice this means:
- the headlamp unit (outer lens, reflector, bulb) shall be type approved to ECE 98 and be “e-marked” to demonstrate this. That can only be done by the headlamp supplier - Hella, Valeo etc. - who must test the headlamp in an independent laboratory
- once fitted to the vehicle it must have headlamp cleaning and self-levelling (which can be for the headlamp or can be in the vehicle suspension - some expensive estate cars have “self-levelling suspension” and that is adequate). Also the dipped beam must stay on with the main beam
- the headlamp must be maintained in good working order, kept clean, and aligned/adjusted correctly in the same way as any other headlamp
- Under the Road Traffic Act 1988 it is an offence to supply, fit or use vehicle parts which are not legal.
In summary: it is not permitted to convert an existing halogen headlamp unit for use with HID bulbs. The entire headlamp unit must be replaced with one designed and approved for use with HID bulbs and it must be installed in accordance with the rules stated above.
So although the car may pass the MOT, it would not be road legal and therefore void car insurance, be subject to a fine if ever caught - but more importantly if in an accident and the oncoming driver was dazzled by the lights, then game over.
At least I now have a post to refer back to those thinking of undertaking this without fitting the levelling and washer systems.