ok - here's what I have drafted for other forums and for several of our customers.
I should perhaps add that I am by trade a legal adviser specialising in road vehicle legislation, and have been so for over twenty years.
The subject of retro-fitting HID headlamps often comes up and is surrounded by all sorts of rumour, theory and half-truth. This statement is intended to cut through and state the requirement for headlamp fitting, legality and beam levelling.
LEGAL REQUIREMENTS
Immediately, there are two very different scenarios to bear in mind on this subject. Those are a set of requirements for a new vehicle type to meet, which I shall call the type-approval requirements and the entirely separate set of requirements that a driver has to ensure his vehicle meets at all times.
Type-approval. This is a Europe-wide system that new vehicles must meet before they can be sold. It consists of 52 separate technical areas, each of which requires compliance with an EU Directive as proven by physical testing. Perhaps the most widely-known of these is the crash test. For headlamps, there are two individual Directives :-
76/761/EEC – Headlamps including bulbs. Includes such things as the light output and beam pattern and a requirement that the headlamp and the bulb is E-marked (or e-marked)
76/756/EEC – Installation of lights. The more important for this issue, as it concerns the installation of the headlamps into the vehicle, especially so that they don’t dazzle other road-users.
As a general summary, the requirements are :- ( and remember these refer to the vehicle as manufacture red )
[ch61607] The headlamp must be approved ( “E” or “e” – marked )
[ch61607] The headlamp bulb must be approved ( “E” or “e” – marked )
[ch61607] The headlamp aim is tested on each vehicle type, with the onus on ensuring that the beam pattern does not rise if the vehicle pitch changes through being loaded more at the rear than the front.
If the vehicle pitch does not change, then beam levelling is not required.
If the vehicle can pitch, then beam levelling is required, which may be manual or automatic.
In addition, if the vehicle is fitted with gas-discharge lamps ( i.e. HiD ), then automatic beam levelling MUST be fitted.
Legal requirements. This is the part that affects a vehicle which has already been sold and is already registered. In the UK the vehicle lighting requirements are given in a special set of Regulations, the Road Vehicle Lighting Regs. These DO NOT enforce the type-approval requirements, so it is in theory possible to modify your vehicle’s lighting away from the type-approved specification, provided that it still falls within the Lighting regs and is otherwise safe (more about this later). It is therefore legal to carry out modifications such as adding fog lamps.
The Road Vehicle Lighting Regs carry specific requirements for headlamps, but these DO NOT include adding suspension self-levelling if the vehicle is retro-fitted with HiD.
For reference, the requirements for headlamps are as follows, from Schedule 4 of the regs :-
Headlamp bulb must be “approved”
Headlamp must be “approved”
Two matching lamps required to be fitted
Must be less than 400mm from the side of the vehicle
Must be between 500mm and 1200mm from the ground
Must be either white or yellow
No wattage requirement for vehicles dating from 1986
Other than the above, there is a more general requirement that the vehicle is maintained so as not to be a danger (Regulation 100 – Road Vehicle Construction & Use Regs). This effectively forces the driver of a vehicle to ensure that it is safe at all times. This would include the beam pattern shown by headlamps.
RETRO-FITTING HiDs
Adding HiD headlamps to a vehicle not originally fitted with them is relatively simple. The vehicle owner must make sure that he stays within the Road Vehicle Lighting Regs and that the vehicle remains safe. It is NOT REQUIRED BY UK LAW that the owner modify the vehicle to the full “type-approval” specification.
Clearly, to ensure the conversion is safe includes making sure the wiring is correct, especially for “flash” and also ensuring that the beam pattern remains the same. This pattern will be acceptable only if the “new” HiD bulb puts out light in the same place as its “filament” counterpart. Whilst this sounds difficult to achieve, in reality there is a readily-available test which is part of the annual MOT.
DfT ADVICE
There is a statement on this issue issued by the Department for Transport, which states that the full “type-approval” specification applies to any retro-fitting activities. As explained above, this is not a requirement of legislation. Even the statement makes clear that it is just “the Department’s view”.
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Topic: HID Conversion Kit (Read 1191 times)