MoT fail - headlight colour incorrect
Discussion
Had a somewhat interesting chat with our MoT tester, who chose to fail Our pre-1986 classic on the basis of, quote, "well it's got LED headlights fitted, but I can't fail them, so I've failed it on incorrect colour instead".
Do I have grounds to challenge, given that the car was first used prior to 1 April 1986, the beam pattern is correct, and the light output is of the correct colour? The same tester passed the car last year with the same bulbs fitted. One of our other pre-86 classics was tested back in May by the same tester with the same LED modules fitted. I'm baffled by this one.
Guidance MOT special notice 01-21: headlamp conversions said:
Class 3,4,5 and 7 vehicles
For class 3,4,5 and 7 vehicles, the defect ‘Light source and lamp not compatible’ only applies to vehicles first used on or after 1 April 1986.
Should a vehicle be presented for an MOT test with conversions before 1 April 1986 they must not be failed with immediate effect.
Vehicles presented with converted halogen headlamp units first used on or after 1 April 1986 will continue to be failed.
Headlamps must comply with all other requirements of the test and headlamp aim.
The car was built in 1983, the beam pattern and aim are perfectly correct, and the LED conversion set as fitted were very expensive units from a reputable supplier. For class 3,4,5 and 7 vehicles, the defect ‘Light source and lamp not compatible’ only applies to vehicles first used on or after 1 April 1986.
Should a vehicle be presented for an MOT test with conversions before 1 April 1986 they must not be failed with immediate effect.
Vehicles presented with converted halogen headlamp units first used on or after 1 April 1986 will continue to be failed.
Headlamps must comply with all other requirements of the test and headlamp aim.
4.1.4. Compliance with requirements said:
The colour of the light headlamps emit must be one of the following:
white
predominantly white with blue tinge
yellow
Defect (a) Headlamp emitted colour, position or intensity not in accordance with the requirements
Category Major
Perhaps my eyes are failing as I get older, but for the life of me I can't see the light output as anything other than white, perhaps with a bluish tinge. white
predominantly white with blue tinge
yellow
Defect (a) Headlamp emitted colour, position or intensity not in accordance with the requirements
Category Major
Do I have grounds to challenge, given that the car was first used prior to 1 April 1986, the beam pattern is correct, and the light output is of the correct colour? The same tester passed the car last year with the same bulbs fitted. One of our other pre-86 classics was tested back in May by the same tester with the same LED modules fitted. I'm baffled by this one.
Quite what the grounds for a fail are, I don't know but I have heard they're clamping down on lights that have had conversions from Halogen to HID. Maybe the MOT tester is being particularly stringent on lighting modifications. Can you not try the good old fashioned swap to normal bulbs for the test and pop them back in after? Assuming your LED light is just a bulb and not a full on ballast and all that stuff, it should be an easy few minutes to swap for the test. Shame it has to come to that though.
Take your car back to the garage, talk it through with them asking for MOT PASS. If they refuse take it somewhere else who understands this element of MOT regs and get PASS certificate. I'm hearing a good few similar tales of MOT garages failing on lights when the replacement bulbs are 100% compliant, don't stand for any nonsense.
If MOT centres have low failure rates they get downgraded on the MOT central system, which is madness :. they are pressured into finding more failures/advisories.
If MOT centres have low failure rates they get downgraded on the MOT central system, which is madness :. they are pressured into finding more failures/advisories.
Thanks all. It's back in for a retest this morning now that I've replaced the (year old perished) rack gaiters and tweaked the emissions. Told the MoT tester that I hadn't changed the bulbs, as I consider them compliant with the MoT requirements - he screwed up his face and grunted. Be interesting to see if it still fails, as we definitely will have a problem then.
Unfortunately replacing the bulbs isn't the work of a moment - need to take the front bumper assembly off as the headlights reside behind it, and it's a right pain in the arse with very limited spanner waggling space. Hence why I fitted the LED bulbs in the first place.
Been using this test centre for well over a decade, they are generally sympathetic to classics and older cars, so I'm loath to go elsewhere unless I really have to. The vast majority of garages around here are of the big brand franchise variety, who couldn't give a monkeys about older cars.
Unfortunately replacing the bulbs isn't the work of a moment - need to take the front bumper assembly off as the headlights reside behind it, and it's a right pain in the arse with very limited spanner waggling space. Hence why I fitted the LED bulbs in the first place.
Been using this test centre for well over a decade, they are generally sympathetic to classics and older cars, so I'm loath to go elsewhere unless I really have to. The vast majority of garages around here are of the big brand franchise variety, who couldn't give a monkeys about older cars.
Roderick Spode said:
Thanks all. It's back in for a retest this morning now that I've replaced the (year old perished) rack gaiters and tweaked the emissions. Told the MoT tester that I hadn't changed the bulbs, as I consider them compliant with the MoT requirements - he screwed up his face and grunted. Be interesting to see if it still fails, as we definitely will have a problem then.
Unfortunately replacing the bulbs isn't the work of a moment - need to take the front bumper assembly off as the headlights reside behind it, and it's a right pain in the arse with very limited spanner waggling space. Hence why I fitted the LED bulbs in the first place.
Been using this test centre for well over a decade, they are generally sympathetic to classics and older cars, so I'm loath to go elsewhere unless I really have to. The vast majority of garages around here are of the big brand franchise variety, who couldn't give a monkeys about older cars.
Out of interest where do you live (roughly!)? We may be able to find you a tester in tune with MOT'ing classics if you dont have any luck with your man.Unfortunately replacing the bulbs isn't the work of a moment - need to take the front bumper assembly off as the headlights reside behind it, and it's a right pain in the arse with very limited spanner waggling space. Hence why I fitted the LED bulbs in the first place.
Been using this test centre for well over a decade, they are generally sympathetic to classics and older cars, so I'm loath to go elsewhere unless I really have to. The vast majority of garages around here are of the big brand franchise variety, who couldn't give a monkeys about older cars.
As an automotive lighting engineer, I've pointed out many times, on many, many threads, that LED bulb upgrades are NOT legal for road use, NONE of them are E approved:
As per this Philips example, HL for off road use (in small print but it's there on the packaging):
https://www.amazon.co.uk/Philips-Ultinon-Pro3021-H...
I'm fully aware that plenty of PHers have gone down the LED bulb route, and have either gotten away with it or swap them out for the MOT.
And I've also pointed out that if you cause an accident and an investigator decides your illegal bulbs were the cause you won't be insured.
The "colour" thing is not the actual reason. The headlamps, and hence the car, are no longer type approved once you start making these modifications.
As per this Philips example, HL for off road use (in small print but it's there on the packaging):
https://www.amazon.co.uk/Philips-Ultinon-Pro3021-H...
I'm fully aware that plenty of PHers have gone down the LED bulb route, and have either gotten away with it or swap them out for the MOT.
And I've also pointed out that if you cause an accident and an investigator decides your illegal bulbs were the cause you won't be insured.
The "colour" thing is not the actual reason. The headlamps, and hence the car, are no longer type approved once you start making these modifications.
Largechris said:
Stuff
The testers manual says "Existing halogen headlamp units on vehicles first used on or after 1 April 1986 must not be converted to be used with high intensity discharge (HID) or light emitting diode (LED) bulbs."And this special notice says "For class 3,4,5 and 7 vehicles, the defect ‘Light source and lamp not compatible’ only applies to vehicles first used on or after 1 April 1986."
Both of these sound to me like you can use LEDs for vehicles pre 1/4/86, or am I missing something?
john2443 said:
Largechris said:
Stuff
The testers manual says "Existing halogen headlamp units on vehicles first used on or after 1 April 1986 must not be converted to be used with high intensity discharge (HID) or light emitting diode (LED) bulbs."And this special notice says "For class 3,4,5 and 7 vehicles, the defect ‘Light source and lamp not compatible’ only applies to vehicles first used on or after 1 April 1986."
Both of these sound to me like you can use LEDs for vehicles pre 1/4/86, or am I missing something?
Guidance MOT special notice 01-21: headlamp conversions said:
Should a vehicle be presented for an MOT test with conversions before 1 April 1986 they must not be failed with immediate effect.
The DVSA said:
Vehicles first used before 1 April 1986 are not required to use type approved ‘e’ marked headlamps. Therefore, converting a halogen, or other headlamp on such a vehicle to use LED bulbs would not be in contravention of the regulations.
v8250 said:
If MOT centres have low failure rates they get downgraded on the MOT central system, which is madness :. they are pressured into finding more failures/advisories.
Interesting you should say this - after a retest this afternoon, with replacement steering rack gaiters, and no other amendments, the car passed without so much as an advisory. When questioned about the previous fail points, the tester said they were now 'okay'.
Largechris said:
As an automotive lighting engineer, I've pointed out many times, on many, many threads, that LED bulb upgrades are NOT legal for road use, NONE of them are E approved:
As per this Philips example, HL for off road use (in small print but it's there on the packaging):
https://www.amazon.co.uk/Philips-Ultinon-Pro3021-H...
I'm fully aware that plenty of PHers have gone down the LED bulb route, and have either gotten away with it or swap them out for the MOT.
And I've also pointed out that if you cause an accident and an investigator decides your illegal bulbs were the cause you won't be insured.
The "colour" thing is not the actual reason. The headlamps, and hence the car, are no longer type approved once you start making these modifications.
I wonder why the industry cannot get them E Approved, it seems that LED or anything that can make things more efficient is the future. I like LED as they take longer to flatten the battery of something is left on and they are often brighter than an ageing normal bulb that fails more frequently.As per this Philips example, HL for off road use (in small print but it's there on the packaging):
https://www.amazon.co.uk/Philips-Ultinon-Pro3021-H...
I'm fully aware that plenty of PHers have gone down the LED bulb route, and have either gotten away with it or swap them out for the MOT.
And I've also pointed out that if you cause an accident and an investigator decides your illegal bulbs were the cause you won't be insured.
The "colour" thing is not the actual reason. The headlamps, and hence the car, are no longer type approved once you start making these modifications.
Caddyshack said:
I wonder why the industry cannot get them E Approved, it seems that LED or anything that can make things more efficient is the future. I like LED as they take longer to flatten the battery of something is left on and they are often brighter than an ageing normal bulb that fails more frequently.
LEDs are E approved for fitting in LED specific lenses (I think these are actually complete headlamp units).My understanding is that replacement bulbs made with LEDs in the same fitting as tradition bulbs (such as H4) are not E approved because the light emitting part of an LED is not the same as a filament in a traditional bulb. As the light emitting part is different so a different shaped lens should be required. The reason a H4 LeD bulb cannot be E approved is that headlights with a H4 fitting have lenses designed for traditional bulbs.
(I may be wrong though, lots of conflicting information out there on the subject).
Scrump said:
Caddyshack said:
I wonder why the industry cannot get them E Approved, it seems that LED or anything that can make things more efficient is the future. I like LED as they take longer to flatten the battery of something is left on and they are often brighter than an ageing normal bulb that fails more frequently.
LEDs are E approved for fitting in LED specific lenses (I think these are actually complete headlamp units).My understanding is that replacement bulbs made with LEDs in the same fitting as tradition bulbs (such as H4) are not E approved because the light emitting part of an LED is not the same as a filament in a traditional bulb. As the light emitting part is different so a different shaped lens should be required. The reason a H4 LeD bulb cannot be E approved is that headlights with a H4 fitting have lenses designed for traditional bulbs.
(I may be wrong though, lots of conflicting information out there on the subject).
Largechris said:
The "colour" thing is not the actual reason.
Firstly, I agree that everything else you say is correct. Aftermarket LED bulbs are not legal and they quite clearly say so.But being pedantic here, the "colour thing" absolutely is the reason it failed. It said so, on the failure notice. In black and white. Couldn't be plainer.
So if that's not right, and in fact the colour is fine, then surely the failure is invalid?
majordad said:
Did you pass the re test ?
Yes indeed. The pass sheet came without so much as an advisory. When I asked the tester about the glaring inconsistency, as to why three Major fail points could magically become not so much as an advisory, and why emissions that were over the limits somehow now sneak under the limits with no outside intervention, the answers there came not. Oddly enough I never received an emissions printout for either the fail or the retest, which makes me suspicical.For reference here's a printout of last year's emissions test - not bad for a near 40 year old car running a single SU, which was completely rebuilt prior to last year's test. Hard to see how it would go from such low readings to over the limits in a year, without significant mechanical problems being evident. Of course it's now passed with no changes whatsoever.
If a test centre is going to (correctly) fail a car on something amiss, but then also bundle on a load of extra fail points to get their quotas up, then I think perhaps it might be time to seek an alternative tester.
Scrump said:
Caddyshack said:
I wonder why the industry cannot get them E Approved, it seems that LED or anything that can make things more efficient is the future. I like LED as they take longer to flatten the battery of something is left on and they are often brighter than an ageing normal bulb that fails more frequently.
LEDs are E approved for fitting in LED specific lenses (I think these are actually complete headlamp units).My understanding is that replacement bulbs made with LEDs in the same fitting as tradition bulbs (such as H4) are not E approved because the light emitting part of an LED is not the same as a filament in a traditional bulb. As the light emitting part is different so a different shaped lens should be required. The reason a H4 LeD bulb cannot be E approved is that headlights with a H4 fitting have lenses designed for traditional bulbs.
(I may be wrong though, lots of conflicting information out there on the subject).
The obvious technical difference that will perhaps make the situation seem more reasonable is that a halogen bulb is emitting typically 2000 lumens (a measure of the actual quantity of light coming out from the surface of all the bulb glass), whereas if you measured an LED bulb in the same way you’d only get maybe 400 lumens.
LED efficiency includes the accurate pointing of the light in specific directions. A halogen emits the light pretty much equally in all directions.
So as you can imagine there is a MASSIVE difference between a headlamp units optics that are designed to collect and focus all the light from an halogen bulb compared to an LED light source.
Interesting and plausable take on it I found on https://www.autobulbsdirect.co.uk/blog/are-led-hea...
"LED upgrade bulbs can’t be classed as road legal because they cannot be E marked or have the British Standard mark.
The reason that LED upgrade bulbs can’t be E marked is simply because no legislation exists for the use of LED technology in a headlight unit built for halogens."
Classic cars make up a very small slice of the car industry pie and those changing to LED headlights a very small piece of that. As such there's probably no pressure on the government to bring in standards, tests, and legislation for H4 LED bulbs so no way for them to pass them and get an "E" mark.
"LED upgrade bulbs can’t be classed as road legal because they cannot be E marked or have the British Standard mark.
The reason that LED upgrade bulbs can’t be E marked is simply because no legislation exists for the use of LED technology in a headlight unit built for halogens."
Classic cars make up a very small slice of the car industry pie and those changing to LED headlights a very small piece of that. As such there's probably no pressure on the government to bring in standards, tests, and legislation for H4 LED bulbs so no way for them to pass them and get an "E" mark.
v8250 said:
If MOT centres have low failure rates they get downgraded on the MOT central system, which is madness :. they are pressured into finding more failures/advisories.
I’ve no wish to derail the thread but this is incorrect. I’ve never come across this in over 30 years of testing.
An MOT tester told me they also get looked into if they dont fail enough cars on different parts of the test, like say suspension faults, brake faults etc so maybe he was looking to get his percentages up.
I take my classic for an MOT every year and tell the tester to be thorough i.e tell me if anything should be done to the car even if it passes the test, but if any garage started to fail the car on stupid things like this I would either find another garage or just not bother with an MOT.
I take my classic for an MOT every year and tell the tester to be thorough i.e tell me if anything should be done to the car even if it passes the test, but if any garage started to fail the car on stupid things like this I would either find another garage or just not bother with an MOT.
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