HID lights and MOT
Discussion
Hi, my car just failed MOT in Ballymena for having HID lights and no washer system. Just another quaint difference between here and the mainland.
DVLA take new MOT regs and write test guides like this:
Vehicles equipped with High Intensity Discharge (HID) or LED dipped beam headlamps MAY be fitted with headlamp washers and a suspension or headlamp self levelling system. Where such systems are fitted, they must work
i.e. if it aint there it don't matter
DVLNI take new MOT regs and write test guides like this:
High Intensity Discharge (HID) and LED dipped beam headlamps (whether original fitment or after-market) MUST be fitted with a headlamp washing system (a wiper is not required) and be self levelling.
Be aware of this important difference. I'm away to glue a supersoaker to my bumper.
DVLA take new MOT regs and write test guides like this:
Vehicles equipped with High Intensity Discharge (HID) or LED dipped beam headlamps MAY be fitted with headlamp washers and a suspension or headlamp self levelling system. Where such systems are fitted, they must work
i.e. if it aint there it don't matter
DVLNI take new MOT regs and write test guides like this:
High Intensity Discharge (HID) and LED dipped beam headlamps (whether original fitment or after-market) MUST be fitted with a headlamp washing system (a wiper is not required) and be self levelling.
Be aware of this important difference. I'm away to glue a supersoaker to my bumper.
In classic PH style I felt compelled to write a strongly worded email. Maybe if they receive enough complaints they may rethink this part of the test. Stranger things have happened.
to dvta@doeni.gov.uk
Hello,
My car just failed MOT in Ballymena for having HID lights and no washer system. I noticed that there is a difference between how the new regs have been applied between Northern Ireland and the Mainland UK.
DVLA take new MOT regs and write test guides like this:
Vehicles equipped with High Intensity Discharge (HID) or LED dipped beam headlamps MAY be fitted with headlamp washers and a suspension or headlamp self levelling system. Where such systems are fitted, they must work
i.e. if it wasn’t originally fitted then it doesn't matter
DVLNI take new MOT regs and write test guides like this:
High Intensity Discharge (HID) and LED dipped beam headlamps (whether original fitment or after-market) MUST be fitted with a headlamp washing system (a wiper is not required) and be self levelling.
I’ve since looked at many different cars as a bit of off the cuff research and noted that many are like mine in that they have factory fitted HID or LED lights and no washer system. Are the DVTA seriously expecting that all of these type approved Audi’s, BMW’s etc will retrofit a washer system to pass the local MOT? It’s a bit high handed when the UK DVLA have not insisted on it.
I’m hoping that this will not be a lone complaint but that you will receive many. I will be encouraging others to lodge their own.
to dvta@doeni.gov.uk
Hello,
My car just failed MOT in Ballymena for having HID lights and no washer system. I noticed that there is a difference between how the new regs have been applied between Northern Ireland and the Mainland UK.
DVLA take new MOT regs and write test guides like this:
Vehicles equipped with High Intensity Discharge (HID) or LED dipped beam headlamps MAY be fitted with headlamp washers and a suspension or headlamp self levelling system. Where such systems are fitted, they must work
i.e. if it wasn’t originally fitted then it doesn't matter
DVLNI take new MOT regs and write test guides like this:
High Intensity Discharge (HID) and LED dipped beam headlamps (whether original fitment or after-market) MUST be fitted with a headlamp washing system (a wiper is not required) and be self levelling.
I’ve since looked at many different cars as a bit of off the cuff research and noted that many are like mine in that they have factory fitted HID or LED lights and no washer system. Are the DVTA seriously expecting that all of these type approved Audi’s, BMW’s etc will retrofit a washer system to pass the local MOT? It’s a bit high handed when the UK DVLA have not insisted on it.
I’m hoping that this will not be a lone complaint but that you will receive many. I will be encouraging others to lodge their own.
If they are dirty it scatters the light and may make them dazzle an oncoming driver. More of an issue with HIDs as they are more intense.
The problem is many cars never had them and if they are not high pressure or have a wiper they really don't clean the lens anyway. You fit a washer system to pass the test not because it actually has any effect.
GB applied the new regs in the same way that the seatbelt regs were applied. Many classics date from before seatbelts were a legal requirement. These old cars get an exemption, if they have no seat belts then that part of the test is not applied. If you fit seat belts (voluntarily) then they must work.
I've written to my MLA as well. Again it's worth a try and I'd be delighted if you could write to yours as well
Find them here
http://aims.niassembly.gov.uk/mlas/Findmlas.aspx
The problem is many cars never had them and if they are not high pressure or have a wiper they really don't clean the lens anyway. You fit a washer system to pass the test not because it actually has any effect.
GB applied the new regs in the same way that the seatbelt regs were applied. Many classics date from before seatbelts were a legal requirement. These old cars get an exemption, if they have no seat belts then that part of the test is not applied. If you fit seat belts (voluntarily) then they must work.
I've written to my MLA as well. Again it's worth a try and I'd be delighted if you could write to yours as well
Find them here
http://aims.niassembly.gov.uk/mlas/Findmlas.aspx
Edited by Oldandslow on Sunday 8th July 14:21
Well it's been 15 working days since I complained to the DVA about my car failing MOT. They promised to reply within 10 working days in line with their complaints procedure. Even though I expect it to be a formal "suck it and do one" reply you'd think they could manage it in a couple of weeks.
Now I've complained about their handling of complaints. This "strongly worded email" stuff is addictive.
Now I've complained about their handling of complaints. This "strongly worded email" stuff is addictive.
I fitted standard type lights and passed a retest. I just don't think it's fair that I had to just because I have a BT postcode.
Apparently they did reply 4 days later. I was sent a scanned copy of a letter this morning. It quotes the EC regulation numbers for type approval and vehicle testing. Apparently the reason for the difference between DVA and VOSA's interpretation is "to take account of a new electric vehicle that has been type approved with HID headlamps and without washers as the headlamps are low output and emit less than 2000 Lumen. DVA will now consider whether a change in the future is required to our testers manual as a result of this information however these vehicles will not be subject to annual test for another 4 years in Northern Ireland."
Now just analysing this quickly
VOSA have written test regs to take account of a single car model that won't need tested for years.
In doing so have created a loophole that allows older cars to pass MOT. Cars that are illegal according to the DVA due to EC type approval regs being retrospective to the beginning of time.
VOSA did not think to write an exemption stating outputs of less than 2000 Lumen.
DVA will rewrite their regs in 4 years, so if you can wait you'll get your HID lights to pass then, unless they think to include a 2000 lumen limit.
The bureaucratic bulls
t is flying back and forth. The DVA seem to be saying VOSA don't know what the fk they are doing. Unfortunately DVA's incompetence is more obstructive.
Apparently they did reply 4 days later. I was sent a scanned copy of a letter this morning. It quotes the EC regulation numbers for type approval and vehicle testing. Apparently the reason for the difference between DVA and VOSA's interpretation is "to take account of a new electric vehicle that has been type approved with HID headlamps and without washers as the headlamps are low output and emit less than 2000 Lumen. DVA will now consider whether a change in the future is required to our testers manual as a result of this information however these vehicles will not be subject to annual test for another 4 years in Northern Ireland."
Now just analysing this quickly
VOSA have written test regs to take account of a single car model that won't need tested for years.
In doing so have created a loophole that allows older cars to pass MOT. Cars that are illegal according to the DVA due to EC type approval regs being retrospective to the beginning of time.
VOSA did not think to write an exemption stating outputs of less than 2000 Lumen.
DVA will rewrite their regs in 4 years, so if you can wait you'll get your HID lights to pass then, unless they think to include a 2000 lumen limit.
The bureaucratic bulls
t is flying back and forth. The DVA seem to be saying VOSA don't know what the fk they are doing. Unfortunately DVA's incompetence is more obstructive.VOSA answered my enquiries to say they wrote their regs to account for the new electric vehicle and not be "too onerous" on the owners of older vehicles. They actually suggested I argue that it was unfair that a type approved vehicle from as recently as 2009, with no defects cannot pass an MOT here. I've already tried that but it's nice that they agree.
Armed with this I repeated my complaints to my MP and MLA's and they forwarded them to Alex Attwood who likely forwarded them to the same person(gritted teeth) I dealt with at DVLNI. The reply I got was pretty much the same except with the added info that the Republic of Ireland has introduced a similar requirement for the NCT. New NCT rules state HID lights must be part of a type approved system (ie not aftermarket conversion) and WILL have an automatic washing system.
Looks like we're stuck with it. Away to recondense my urine.
Armed with this I repeated my complaints to my MP and MLA's and they forwarded them to Alex Attwood who likely forwarded them to the same person(gritted teeth) I dealt with at DVLNI. The reply I got was pretty much the same except with the added info that the Republic of Ireland has introduced a similar requirement for the NCT. New NCT rules state HID lights must be part of a type approved system (ie not aftermarket conversion) and WILL have an automatic washing system.
Looks like we're stuck with it. Away to recondense my urine.
Depends on your situation. For me it was 2nd hand lights for £60 of Ebay and fitted myself. My mechanic aligned them for free because he's a star but it probably wouldn't cost too much. I imagine if you went to a main dealer to replace your lights it would be very pricey. Brand new set of lights, fitting and alignment at dealer labour rates adds up pretty fast.
How come he can apply an exemption for SRS MIL's giving customers the "benefit of the doubt" because some cars didn't have it before it became mandatory and yet in the same circumstances not give one for HID headlight washers?
It's a 2 point letter and he contradicts himself. The mind boggles.
It's a 2 point letter and he contradicts himself. The mind boggles.
Glimmer of hope. A Caseworker in the office of William McCrea is digging deeper. He contacted VOSA and they told him they are "baffled" by the NI regulation. He's looking into how the regs are being implemented across Europe to see if there is a consensus. Just be our luck if VOSA are on their own 
My car is 12 years old from before it was a requirement to have washers. There are many older cars with type approved HID lights that don't meet the requirements of the NI test.
Yes, the test has changed in GB too. Our point is that the test requirements in GB are different. Simply put my car will pass in a GB VOSA test station but not in an NI test station
Yes, the test has changed in GB too. Our point is that the test requirements in GB are different. Simply put my car will pass in a GB VOSA test station but not in an NI test station
Yes, the loom is slightly different between the HID and incandescent bulb cars. I also freely accept that my car is an import and that modifications will be required to suit UK regs. I didn't complain about fitting a fog light or converting my speedo to read miles and kms.
This time though I felt it was unfair that it was a postcode issue, if I lived in England my car would have been fine as it was and not needed new lights. I probably would have left it at that but then I found out that the type approval regs only changed in 2010 and that European type approved cars sold into the UK were falling foul of the same difference in the NI regs.
This time though I felt it was unfair that it was a postcode issue, if I lived in England my car would have been fine as it was and not needed new lights. I probably would have left it at that but then I found out that the type approval regs only changed in 2010 and that European type approved cars sold into the UK were falling foul of the same difference in the NI regs.
Well 2010 was the info I got from DVLNI and VOSA when I enquired about why the MOT regs changed for 2012. Both said that it was the changes in 2010 that introduced the need for checks to the MOT and their different interpretation of what was required. It doesn't really matter, my concern is that you are treated differently in NI than in GB.
Renault-
If you don't try to change things then they never will. It may change nothing but at least I tried.
Oldandslow said:
Where such systems are fitted, they must work
Really? This is the crucial phrase from my very first post. It's from VOSA's MOT test manual. It all turns on this. If your car has washers they must work. If your car does not have washers then it passes.If you don't try to change things then they never will. It may change nothing but at least I tried.
Gassing Station | Northern Ireland | Top of Page | What's New | My Stuff