Legality of retrofit LED headlight bulbs?
Legality of retrofit LED headlight bulbs?
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Discussion

mjb1

Original Poster:

2,585 posts

188 months

Thursday 10th October 2019
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Trying to get clarification on the legality of retrofit/after market led headlight bulbs - I always thought there was no way this could be done legally, they couldn't possibly have obtained E mark approval etc?

The headlights in question take a H11 bulb behind a projector lens for dipped beam and HB3 reflector main beam, and the vehicle model has been on the market since 2012. In the last year or so, the manufacturer has started offering 'LED upgrade kits' as an official product through their dealer network. Apparently they are very good, give a good even beam pattern with sharp cut off and no glare etc. Which is all quite possible, but can they really be technically road legal?

SlimJim16v

8,079 posts

172 months

Thursday 10th October 2019
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Not sure if it only applied to HID, but they were legal if under 2,000 lumens. Though I think recent changes have stopped this?

markjmd

563 posts

97 months

Thursday 10th October 2019
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If it's supplied/manufactured by the dealer, it's not unreasonable to assume it will be of the same design and quality as a factory-fit part for a newer version of the same model, and therefore fully legal.

Also, if it's dealer-supplied, that would generally mean the opposite of after-market.

mjb1

Original Poster:

2,585 posts

188 months

Friday 11th October 2019
quotequote all
markjmd said:
If it's supplied/manufactured by the dealer, it's not unreasonable to assume it will be of the same design and quality as a factory-fit part for a newer version of the same model, and therefore fully legal.

Also, if it's dealer-supplied, that would generally mean the opposite of after-market.
The current version is still supplied with incandescent H11 bulbs, they've never been supplied from the factory with LED headlights, just the UK distributor offering them as an OEM upgrade. I don't know any manufacturer that does oem LED headlights with a traditional bulb fitting? Aren't they all bespoke units/modules? If it's possible to get LED 'bulbs' in traditional packaging that meet legislation, wouldn't everyone be selling them a road legal? Everywhere you look, it's stated that these type of retrofit LEDs aren't legal for road use.

And it further seems odd that the packaging doesn't look at all oem - it's just some random generic box with a sticker that has the UK distributor's product code on it. I think it's just the UK distributor getting some cheap generic Chinese LED kits, tested them and found they look ok, and are peddling them as manufacturer approved at what appears to be a rather inflated price.

Chris32345

2,141 posts

91 months

Friday 11th October 2019
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Led lights are only legal in a light housing designed for them
Therefore there can't be a legal retrofitting options

Riley Blue

23,205 posts

255 months

Friday 11th October 2019
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Chris32345 said:
Led lights are only legal in a light housing designed for them
Therefore there can't be a legal retrofitting options
Can you point me to the relevant regulation or legislation as I was just about to buy some H4 LED bulbs to fit my Riley.

Jeremy-75qq8

1,748 posts

121 months

Friday 11th October 2019
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Out of interest why is that ?

As long as correctly focused I am surprised there is anything that specifies the type of bulb.


eldar

25,262 posts

225 months

Friday 11th October 2019
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Chris32345 said:
Led lights are only legal in a light housing designed for them
Therefore there can't be a legal retrofitting options
The regulations around lighting are not straightforward, wattage, technology and light output all seem to be variable.

For example my 2018 car had HID headlamps as standard fit, but no washers or auto adjust.

It’s hard to find a clear interpretation of what the regulations actually mean.

emperorburger

1,484 posts

95 months

Friday 11th October 2019
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eldar said:
The regulations around lighting are not straightforward, wattage, technology and light output all seem to be variable.

For example my 2018 car had HID headlamps as standard fit, but no washers or auto adjust.

It’s hard to find a clear interpretation of what the regulations actually mean.
I think Ford fitted lower wattage HID bulbs on the Mustang when brought over to Europe to circumvent the requirement for self levelling and washers.

Initforthemoney

743 posts

173 months

Friday 11th October 2019
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Indeed, although I think most manufacturers are doing this to reduce cost/weight etc.

Even some factory fit headlights are 2000lm to avoid it.


Heidfirst

200 posts

116 months

Friday 11th October 2019
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Riley Blue said:
Can you point me to the relevant regulation or legislation as I was just about to buy some H4 LED bulbs to fit my Riley.
Have fun https://globalautoregs.com/rules/147-light-emittin... :P

Essentially, they aren't type approved/E-marked currently so not road legal.

eldar

25,262 posts

225 months

Friday 11th October 2019
quotequote all
emperorburger said:
I think Ford fitted lower wattage HID bulbs on the Mustang when brought over to Europe to circumvent the requirement for self levelling and washers.
You are quite correct, thanks. I hadn’t spotted that.

NewUsername

925 posts

85 months

Friday 11th October 2019
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If your lights are projector type and you stick in an LED and the beam pattern is ok ( ie passes the MOT) then in my experience you wont have any issues.

I've been running a £20 set of LEDS in my car for the last 2 years purely because i drive a lot at night in the countryside and they are immeasurabely better then the halogens i took out.

If your lights are reflector type then you wont get a decent beam pattern

rambo19

2,951 posts

166 months

Friday 11th October 2019
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I put after market led bulbs in my land rover 110, passed mot no problems.

Roo

11,504 posts

236 months

Friday 11th October 2019
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eldar said:
emperorburger said:
I think Ford fitted lower wattage HID bulbs on the Mustang when brought over to Europe to circumvent the requirement for self levelling and washers.
You are quite correct, thanks. I hadn’t spotted that.
Yep. And everyone moans about how rubbish they are.

Heidfirst

200 posts

116 months

Friday 11th October 2019
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rambo19 said:
I put after market led bulbs in my land rover 110, passed mot no problems.
just because it passes an MOT doesn't mean that it is road legal ...

Stoofa

959 posts

197 months

Saturday 12th October 2019
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Heidfirst said:
rambo19 said:
I put after market led bulbs in my land rover 110, passed mot no problems.
just because it passes an MOT doesn't mean that it is road legal ...
Indeed - but this concept seems to be a difficult one to comprehend at PH.
The same thing is said in the numberplate threads when we're told how an MOT was passed with luminous green plates with invisible ink - it says far less about the legality of the vehicle and far more about how poor your chosen MOT tester is.

Tomo1971

1,177 posts

186 months

Saturday 12th October 2019
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Take a read of this, although mainly re HID upgrades it is relevant to LED as the beam pattern is different to what was designed.

http://www.danielsternlighting.com/tech/bulbs/Hid/...

From my own experience of HID kits in a few cars a few years back, those in reflector headlamp units are dire, they dazzle low flying aircraft let alone cars - those in projector units, although the cut off is far better, the beam spread / pattern on the road ahead is diabolical - the bright spots on the road ahead are in the wring place and focuses your eyes to the wrong area - i used to get eye strain with them. My two recent cars have had factory Xenon and now Full LED - the difference between aftermarket and factory is very clear.

I also found, due to the fitting of the HID bulbs into the headlamp unit, the physical bulk of the bit behind the 'bulb', I had to modify the bulb entry and was no longer waterproof and so would very quickly suffer from condensation. Appreciate that not all will be the same size and may not have that particular issue.

Get a torch and stand in front of a mirror - shine torch at mirror a couple of cm away and you get a light beam on the wall behind you. Move the torch just 1mm and the light beam behind will move by several mm - now imagine the back of a reflector headlamp unit with hundreds of mirrors.... and the fact that the halogen filament is in the same place on EVERY make of bulb of that type - the unit is made to match the location of the filament. HID and LED dont have that filament but their source of light is in a different place to what the headlamp unit is designed for.... so the light emitted, can ONLY be different pattern.

The 'shutters' that are built into the newer aftermarket kits only reduce the dazzle above the beam cut off, they do nothing to tighten up the beam pattern on the road.


Tomo1971

1,177 posts

186 months

Saturday 12th October 2019
quotequote all
mjb1 said:
Trying to get clarification on the legality of retrofit/after market led headlight bulbs - I always thought there was no way this could be done legally, they couldn't possibly have obtained E mark approval etc?

The headlights in question take a H11 bulb behind a projector lens for dipped beam and HB3 reflector main beam, and the vehicle model has been on the market since 2012. In the last year or so, the manufacturer has started offering 'LED upgrade kits' as an official product through their dealer network. Apparently they are very good, give a good even beam pattern with sharp cut off and no glare etc. Which is all quite possible, but can they really be technically road legal?
If the car maker offers kits then they may be a whole replacement of the headlamp - if so, thats the way to go - dont bother with aftermarket HID or LED bulbs, see my other post.

I do believe that (with factory xenon anyway), if they are below a certain lumen, they dont need washers or auto levelling - believe that some vauxhall's employed this type of install a few years ago - maybe one of the sportier corsa models? Maybe the same thinking with full LED?

lyonspride

2,978 posts

184 months

Saturday 12th October 2019
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I was under the impression that LED lighting is not legal at all under UK law "The Road Vehicles Lighting Regulations 1989", because in 1989 LED lights did not exist.
We allow them because they pass EU standards and we basically have no choice in the matter.

What this means is that if an LED "bulb" fails, you cannot replace it, you must replace the whole lamp in order for it to meet the EU standards by which we allow them in the UK.

And by the same token, this means that any retrofit LED bulb is technically illegal.