# The ********** HID Legality Thread - From the DfT



## Nanoman (Jan 17, 2009)

Aftermarket HID Headlamps

Statement
This document provides general guidance and advice on the legislative requirements in Great Britain relating to aftermarket HID headlamps. Every effort has been made to ensure that it is factually correct but recipients should check with the producers of this document if they have reason to believe any part is not correct or is now out of date.

General requirements

In the Department for Transport's (DfT) view it is not legal to sell or use after market HID lighting kits, for converting conventional Halogen headlamps to HID Xenon. If a customer wants to convert his vehicle to Xenon HID he must purchase completely new Xenon HID headlamps. The reason for this is that the existing lens and reflector are designed around a Halogen filament bulb, working to very precise tolerances. If one places a HID "burner" (bulb) in the headlamp, the beam pattern will not be correct, there will be glare in some places and not enough light in other places within the beam pattern.

The following is the legal rationale:

The Road Vehicle Lighting Regulations 1989 regulate the situation in the UK.
*Under these Regulations, HID/Gas Discharge/Xenon headlamps are not mentioned and therefore they are not permitted according to the strict letter of the law. *

However new vehicles have HID headlamps. This is because they comply with European type approval regulations. The UK cannot refuse to register a vehicle with a European type approval. These approvals relate to ECE Regulation 98 (for the HID headlamps which are tested on a rig in a laboratory) and ECE Regulation 48 (lighting installation on the vehicle).

For the aftermarket, a used vehicle cannot obtain type approval because this only applies to new vehicles. *However DfT does not think it reasonable simply to ban HID in the aftermarket.* Instead the Department makes analogies with new vehicles. It seems reasonable to require HID in the aftermarket to meet the same safety standards as those for new vehicles. The same level of safety should apply.

Therefore a HID headlamp unit sold in the aftermarket should: 
1.	be type approved to ECE Regulation 98 as a component; 
2.	when fitted to the vehicle should enable ECE Regulation 48 to be complied with (although no government inspection will take place); and
3.	comply with RVLR as far as "use" is concerned.

*In practice this means:
1.	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.
2.	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. 
3.	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.*

Further information
A note on legislation for vehicle lighting is annexed to this information sheet.
If you require any further information regarding the content of this information sheet, please contact the DfT at the address below:

International Vehicle Standards
Department for Transport
Zone 1/33
Great Minster House
33 Horseferry Road 
London 
SW1P 4DR 
Telephone: 020 7944 2091
Fax: 020 7944 2196
Email: [email protected]

NOTE: The information in this document is a summary of DfT's understanding of what the law requires. However, ultimately the interpretation of the law is a matter for the courts based on individual facts of any particular case. You are therefore advised to consult the relevant legislation and, if necessary, seek independent advice.

GB Road Vehicle Lighting Regulations

The Statutory Instruments which make up the GB Road Vehicle Lighting Regulations are available on the Legislation website of The Office of Public Sector Information (OPSI) http://www.opsi.gov.uk/ as follows:

Base Regulation: 
The Road Vehicles Lighting Regulations 1989: 
Statutory Instrument (S.I.) 1989 No.1796 
http://www.opsi.gov.uk/si/si1989/Uksi_19891796_en_1.htm

As amended by:
The Road Vehicles Lighting (Amendment) Regulations 1994:
S.I. 1994 No.2280
http://www.opsi.gov.uk/si/si1994/Uksi_19942280_en_1.htm

The Road Vehicles Lighting (Amendment) Regulations 1996:
S.I. 1996 No.3016
http://www.opsi.gov.uk/si/si1996/Uksi_19963016_en_1.htm

The Road Vehicles Lighting (Amendment) Regulations 2001:
S.I. 2001 No.560
http://www.opsi.gov.uk/si/si2001/20010560.htm

The Road Vehicles Lighting (Amendment) Regulations 2005:
S.I. 2005 No.2559
http://www.opsi.gov.uk/si/si2005/20052559.htm

The Road Vehicles Lighting (Amendment) Regulations 2005:
S.I. 2005 No.3169
http://www.opsi.gov.uk/si/si2005/20053169.htm

The Road Vehicles Lighting and Goods Vehicles (Plating and Testing)(Amendment) Regulations 2009:
S.I. 2009 No.3220
http://www.opsi.gov.uk/si/si2009/uksi_20093220_en_1

Other minor and consequential amendments:
The Consumer Protection from Unfair Trading Regulations 2008
NB. See Schedule 2 paragraph 82
http://www.opsi.gov.uk/si/si2008/uksi_20081277_en_1

The Fire and Rescue Services Act 2004 (Consequential
Amendments) (England) Order 2004
NB. See paragraph 19
http://www.opsi.gov.uk/si/si2004/uksi_20043168_en.pdf

The Serious Organised Crime and Police Act 2005 (Consequential and Supplementary Amendments to Secondary Legislation Order 2006)
NB. See paragraph 9
http://www.opsi.gov.uk/si/si2006/uksi_20060594_en.pdf

Tramcars and Trolley Vehicles (Modification of Enactments) Regulations 1992
NB. See Part V paragraph 14
http://www.opsi.gov.uk/si/si1992/Uksi_19921217_en_1.htm

The Medical Act 1983 (Amendment) and Miscellaneous
Amendments Order 2006 
NB. See paragraph 76
http://www.opsi.gov.uk/si/si2006/uksi_20061914_en.pdf

Paper copies of Statutory Instruments are available for purchase from The Stationery Office at:

TSO Orders/Post Cash Department
PO Box 29
Norwich
NR3 1GN
Tel: 0870 600 5522
Fax: 0870 600 5533
Email: [email protected]
Website: www.tsoshop.co.uk

***

EU Directives can be found at:
http://ec.europa.eu/enterprise/sectors/automotive/documents/directives/index_en.htm
(The above lists all Directives pertaining to road and agricultural vehicles)

UN-ECE Regulations can be found at: http://www.unece.org/trans/main/wp29/wp29regs.html

Paper copies of Directives can be ordered from TSO (see contact details above) or from the Vehicle Certification Agency (VCA) at:

Tel: +44 (0)117 952 4178 or
+44 (0)117 952 4143 
Email: [email protected]


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## SteveTDCi (Feb 8, 2006)

Precise tolerances .. It's a bulb held in by a spring. So that's them effectively banned as retro fitting self levelling is going to be out of the question financially


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## Rob_Quads (Jul 17, 2006)

> NOTE: The information in this document is a summary of DfT's understanding of what the law requires. However, ultimately the interpretation of the law is a matter for the courts based on individual facts of any particular case. You are therefore advised to consult the relevant legislation and, if necessary, seek independent advice.


Hmm interesting sentence i.e. we think this might be right but we are not really sure. :lol:


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## PugIain (Jun 28, 2006)

Im interested in HIDs but from a scrap 407,so not aftermarket.Not sure whats what to be honest.


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## amiller (Jan 1, 2009)

As a nighttime driver I hate HIDs. Poorly set up lights are nothing short of dangerous. Ban them.


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## 182_Blue (Oct 25, 2005)

Most HIDs I see in normal reflective headlights look naff and are dangerous to other road users, I'm all for having them banned and removed and users being fined and getting points etc etc, the only exception being proper xenon headlights retro fitted from a doner car.


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## Nanoman (Jan 17, 2009)

The message I get is that as long as you change the entire unit for a type approved unit you're fine. I'm with Steve as I suspect this will make it prohibatively expensive. Manufacturing and type approving headlight units for every model including self-levelling and cleaning function will be very expensive. Also if you fit a type approved unit that doesn't function properly you're illegal.



PugIain said:


> Im interested in HIDs but from a scrap 407,so not aftermarket.Not sure whats what to be honest.


If they are original fit on the scrapper and you change the entire headlight unit and wire it correctly so it functions as it was supposed to you'll be fine i.e. if it's got self levelling within the headlight unit you'll need to make sure it works once fitted to yours and you'll need headlamp washers. I suspect the only thing to check is if the scrapper had self levelling suspension you'll need it too i.e. if it only received type approval because self-levelling suspension was fitted. I suppose that's not very likely on the 407.


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## PugIain (Jun 28, 2006)

Ive just texted my friend who had a 407 exec and his had the same levelling system as mine but also headlamp washers.
Which mine hasnt got.So Maybe not worth the hassle.


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## bidderman1969 (Oct 20, 2006)

So it's saying "we'll ban them, but maybe not ban them"

?


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## SteveTDCi (Feb 8, 2006)

Its saying they are illegal unless you fit automatic levelling, wash systems and fit them in a headlight that is type approved for use with a xenon bulb. 

Technically they are not banning them, realsitically the costs involved are going to be to expensive to make economical sense, its like trying to force people off the roads, they just drive up the cost of fuel to a point where people can no longer afford it.


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## MidlandsCarCare (Feb 18, 2006)

So only a full OEM retro fit is legal?


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## CraigQQ (Jan 20, 2011)

thats the way I read it russ.

and I'm with andy on this.. aftermarket HID conversion kits are nothing but a pain, look stupid and fake, and I would also say BAN THEM!

for instance, my car has xenon's for the lower models to convert theirs they would need to buy.. 
the headlights, the bumper(to get the washer system(tubes are already there on standard models, just nothing to connect to) and the sensors from the suspension that level the headlights.

from a second hand car, that would be expensive I would think


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## Dannbodge (Sep 26, 2010)

Still keeping mine in.
My lights are always clean and are perfectly aligned with the beam pattern no different to my dad's BMW and whenever I have any more than 1 person in the car, I dip my lights to make sure they don't blind people.


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## nick_mcuk (Jan 4, 2008)

Finally!!! 

Ok I have Xenons on the A6 but it came out of the factory like that...the amount of times I have been blinded by some norbert who has fitted an aftemarket kit in to the standard headlights...I have lost count.

I welcome this banning of them and hoepfully it will knock the sales of these effing kits!

Not ot metion bikes that fit them....


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## Rob_Quads (Jul 17, 2006)

While there are many aftermarket kits that are blinding there are also a lot of cars who's standard Xenons are blinding.


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## Grizzle (Jul 12, 2006)

nick_mcuk said:


> Finally!!!
> 
> Ok I have Xenons on the A6 but it came out of the factory like that...the amount of times I have been blinded by some norbert who has fitted an aftemarket kit in to the standard headlights...I have lost count.
> 
> ...


Every single word above is what i was going to say (maybe not as posh lol)

Even some OEM Xenon's are blinding such as the Range Rovers.


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## Yowfailed (Mar 14, 2012)

nick_mcuk said:


> Finally!!!
> 
> Ok I have Xenons on the A6 but it came out of the factory like that...the amount of times I have been blinded by some norbert who has fitted an aftemarket kit in to the standard headlights...I have lost count.
> 
> ...


I am in exactly the same position with regard to chosen car and option pack to include Zenon headlamps, at a cost!.

I would agree that these aftermarket HID systems are nothing more than a pain in the A***. They are usually poorly fitted and more importantly, very badly aligned.

As an aside, an MOT tester friend of mine said that the dealership that he works at have said that any aftermarket fitments they test have to be spot on or they will fail the MOT. There is also a suggestion that MOT guidelines are due another overhaul with HID systems being considered :thumb:


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## Lee.GTi180 (Apr 28, 2010)

Dannbodge said:


> Still keeping mine in.
> My lights are always clean and are perfectly aligned with the beam pattern *no different to my dad's BMW *and whenever I have any more than 1 person in the car, I dip my lights to make sure they don't blind people.


The BMW will have projector headlights, does your's have projectors or reflectors? As there's a major difference when it comes to HID.


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## SteveyG (Apr 1, 2007)

Dannbodge said:


> My lights are always clean and are perfectly aligned with the beam pattern no different to my dad's BMW


Doubtful. The cutoff might be reasonably ok to you by eye, but how have you measured the light distribution?


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## Dannbodge (Sep 26, 2010)

Lee.GTi180 said:


> The BMW will have projector headlights, does your's have projectors or reflectors? As there's a major difference when it comes to HID.


I have projectors :thumb:



SteveyG said:


> Doubtful. The cutoff might be reasonably ok to you by eye, but how have you measured the light distribution?


Looks no different and I've never had any problems with MOTs so it's got to be alright?


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## Grizzle (Jul 12, 2006)

OEM Xenons dont always have projector headlights, Volvo XC90 doesnt as does the Nissan Pathfinder


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## SteveTDCi (Feb 8, 2006)

MidlandsCarCare said:


> So only a full OEM retro fit is legal?


No After market xenon kits are no illegal, they can be fitted providing they are in a type approved headlamp, have a means of cleaning and self leveling. Xenons are a great idea, mine turn too and i love them.

Our TT has them as well but picked up an advisory because the self leveling bracket on the rear has broken, the MOT station manually adjusted them and it passed, I just need to fix the link arm.

You could retro fit xenons but you have got to be looking at the best part of £1500.


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## kings.. (Aug 28, 2007)

I recently read an update from vosa at my mates garage whilst having an mot.. it states should the vehicle be fitted with self levelling and headlamp washers they need to be operating correctly, it also mentions should the bulb be emitting a blue tinge it would become a failure.. in the MOT guidance it doesn't mention HID's being illegal if retrofitted; although if they are fitted to non projector/HID ready headlamps the beam scatter is generally inaccurate.

I have fitted HID's on many cars ive owned and not once had a failure or a tug from the police... I don't honestly know what the big deal is! surely better lighting improves road safety? and it doesn't justify thread after thread about the "alleged" legalities surrounding their usage.


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## SteveyG (Apr 1, 2007)

kings.. said:


> I don't honestly know what the big deal is! surely better lighting improves road safety? and it doesn't justify thread after thread about the "alleged" legalities surrounding their usage.


The main problem is for other road users. I've had to brake heavily to about 15mph on a dark national speed limit road because the glare from an oncoming vehicle was so bad that I could hardly see. These headlamps are not designed to increase the brightness in the foreground - if you compare halogen and HID headlamps side by side you should notice that the foreground is similarly illuminated. However they have an increased hot spot close to the cut off, which improves distance vision.

When people use these HID kits, the headlamp unit hasn't been optimised for the increased light output from a HID lamp, so floods the foreground with extra light reducing the users' distance vision.

The 'thanks' was unintentional btw. Lol. :wave:


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## bigmc (Mar 22, 2010)

SteveTDCi said:


> No After market xenon kits are no illegal, they can be fitted providing they are in a type approved headlamp, have a means of cleaning and self leveling. Xenons are a great idea, mine turn too and i love them.
> 
> Our TT has them as well but picked up an advisory because the self leveling bracket on the rear has broken, the MOT station manually adjusted them and it passed, I just need to fix the link arm.
> 
> You could retro fit xenons but you have got to be looking at the best part of £1500.


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.

You can't fit a HID burner in a halogen headlamp end of story. It is illegal to convert a halogen headlamp to hid.


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## Dannbodge (Sep 26, 2010)

I'm going to talk to the Vauxhall garage I take mine to before getting it's MOT done, if they say it's a fail I'll go to one where I know it will pass.
If everywhere says it will fail, the bulbs will be changed for decent ones.

As long as people have them in projector lights that are correctly aligned, I don't see the issue. It's all the chavs in their saxos that have them in reflector headlights and not aligned that are the issue.


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## SteveTDCi (Feb 8, 2006)

bigmc said:


> 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.
> 
> You can't fit a HID burner in a halogen headlamp end of story. It is illegal to convert a halogen headlamp to hid.


Correct, but you can fit one in an approved headlamp, or thats how I read it


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## bigmc (Mar 22, 2010)

SteveTDCi said:


> Correct, but you can fit one in an approved headlamp, or thats how I read it


Yes but a headlamp approved for HID wouldn't be approved for a halogen lamp and vice versa. Without trying to sound condescending or pedantic, halogen lamps are made to really stringent tolerances (circa 200um for the position of the filament or reflector in a H4), a hid burner emits light from the whole gas tube rather than just from the filament or reflector. It's an argument that will go on and on until someone writes something **********, but the way I read that reg from the DFT is you can't put a hid burner in a halogen lamp.


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## Rob_Quads (Jul 17, 2006)

SteveTDCi said:


> Our TT has them as well but picked up an advisory because the self leveling bracket on the rear has broken, the MOT station manually adjusted them and it passed, I just need to fix the link arm..


lol - So the MOT station passed the car when it should have failed as the lights could not auto-level. "I know you will fix it so I'll just mark it down as a pass"


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## SteveTDCi (Feb 8, 2006)

Rob_Quads said:


> lol - So the MOT station passed the car when it should have failed as the lights could not auto-level. "I know you will fix it so I'll just mark it down as a pass"


It went as an advisory, this was in January when it wasn't a failure, it was April when it becomes a fail.


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## SteveTDCi (Feb 8, 2006)

bigmc said:


> Yes but a headlamp approved for HID wouldn't be approved for a halogen lamp and vice versa. Without trying to sound condescending or pedantic, halogen lamps are made to really stringent tolerances (circa 200um for the position of the filament or reflector in a H4), a hid burner emits light from the whole gas tube rather than just from the filament or reflector. It's an argument that will go on and on until someone writes something **********, but the way I read that reg from the DFT is you can't put a hid burner in a halogen lamp.


Its not coming across like that :thumb:


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## Laurie.J.M (Jun 23, 2011)

There are proper kits available. The Retrofit Source sell properly designed bi-xenon projectors that with a bit of work can be fitted to just about any set of headlights, reflectors and sealed beams included. The kits can be ordered for driving on the left aren't actually that expensive particularly when you consider what you're getting and looking at the light output pics they're better than some OEM units I've seen. They don't come with the washers or self levelers as they aren't required in the USA but if those parts were made available as an aftermarket kit that would certainly be a way to get legal xenon headlights at a fairly reasonable cost.

EDIT: on another note, Hella do make both auto-levelling and headlamp washer kits (static and pop out) for aftermarket and OEM for small volume cars I've just got no idea how where to get the bits from or how much it costs.

Surely to get auto levelling all you would need is a kit that would consist of some sensors to detect the cars ride height at the rear and then a module that goes on the existing electric headlamp levelers to make the headlights go up and down on their own rather than using the switch in the car. I'm also interested to find out what the stance is on american cars and grey imports that come over with OEM xenon lights fitted as quite a few won't have auto leveling or washers as they're not required by law where the car came from.


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## Nanoman (Jan 17, 2009)

kings.. said:


> it doesn't justify thread after thread about the "alleged" legalities surrounding their usage.


My OP is not "alleged" and is in fact as ********** as you can get. The only thing which will affect it is new legislation or new legal cases which set precedence (that's why there's the additional note about legal interpretation).

I was contemplating fitting HIDs to my motorbike but due to the short wheelbase on a bike dazzling other road users is a real issue. There's a lot of debate on a lot of forums so I took the time to contact the DfT for the ********** word.


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## PugIain (Jun 28, 2006)

Mine has levellers and projecters so the bits and bobs would go straight in.
But it doesnt have the washer system,which would probably be a massive nuisance to fit and make work correctly.
So to be honest I think it isnt worth the bother.


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## SteveTDCi (Feb 8, 2006)

They would need to be auto levellers, the wash system should be easy bang a couple of washer jets on the front bumper


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## Paintmaster1982 (Oct 23, 2007)

Do headlight washers actually work though. In the winter time i clean my lights pretty much every day as the ****e that comes off the motorways covers them almost instantly.

I find i have to wipe them with a cloth to clean them properly surely the washer jets wont really clean them?


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## Laurie.J.M (Jun 23, 2011)

Paintmaster1982 said:


> Do headlight washers actually work though. In the winter time i clean my lights pretty much every day as the ****e that comes off the motorways covers them almost instantly.
> 
> I find i have to wipe them with a cloth to clean them properly surely the washer jets wont really clean them?


It does rely on people actually using them, on our Honda CR-V the headlight washers come on with the windscreen washers when the lights are on where as on the Mercedes you have to use the button on the dashboard. They do work quite well but they're not perfect, the water goes all over the bonnet and down the bumper leaving streaky marks plus at night the they render the lights useless for a few seconds.


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