robertspark Posted February 16, 2015 Share Posted February 16, 2015 Nick is well read, and spot on with his posts, I always try to reference my posts to avoid expressing an opinion, but at the end of the day everything on a forum is opinion, and fact is what you decide it is from your perspective IANAL (new abbreviation of the day, thanks Nick!). It all comes back to these documents in my opinion: http://www.unece.org/fileadmin/DAM/trans/main/wp29/wp29regs/2013/R112r3e.doc http://www.unece.org/fileadmin/DAM/trans/main/wp29/wp29regs/2013/R113r3e.doc yes there is a minor difference in the documents, hence the Regulation 113 document is probably more applicable to the way that the IVA is treating LED's the same (almost) as HID's. The long and the short is, yes no doubt that there are light fittings that are fraudulently marked and marketed (maybe same as all other products on the market), but as a consumer you would be hard pressed to verify this and it would be something very difficult to be prosecuted on the basis of given you asked all the relevant questions and attempted to get the correct product which though no fault or fraudulent activity of your own was later proved to be counterfeit. Lets try this from a different angle, you decide to by a set of Osram Day Breakers to your vehicle.... are you still legal? My argument would be no .... possibly .... , as the headlamps you've just put them into were designed for a specific set of H4 (say) halogen lamps upon which their parametrics were tested against the ECE tests, which include a directional lux (candella) tests. Now adding a set of lamps that you clearly know have "improved" light output makes the whole fitting non-compliant .... possibly.... lets say for arguments sake when the headlights were originally tested the parametrics obtained indicated that they met or were slightly under the limiting lux (or candela) level at the specific point in the feild of view (at the end of the day the objective of the designer and manufacturer is to target the limiting numbers and then just cut back so their lamps are the "best performing" to meet (or be just below, as above would be an automatic fail) of the regs. The limiting number is 350 lux Check out the "regulation 122" document above, which specifically deals with halogen lamps, page 18/73 there is a table that shows a load of test points, top one on the list is point "B 50 L", and the maximum intensity of both (all) classes of halogen lamps is 350 candela (lux). Great lets say your light fitting well designed by Landrover's product development team / subcontractor hits 300 candela (~17% below the limiting number, which is great as it allows for lamp variation [probably a little too large, but what do I know about product development], but lets run with it for a second). The Osram Night Breaker lamps are 110% brighter than whatever a standard / normal run of the mill halogen lamp is. With 20% whiter light... So by installing Night Breakers, in your old fitting you've effectively just increased the performance of the fitting by 110% , great, but that point illuminance for the "E" marked fitting compliance has just gone from 300 candela to say 600 candela potentially (100% light improvement....same parametrics) but the limit was 350 cd.... your fitting sir is now non-compliant and you full well knowing fitted a non-compliant lamp on the basis that it was advertised in full view and publicity as being just that a >100% light output lamp so is not a manufacturer standard lamp ..... never mind VOSA (et al) chasing after LED's I'd be getting the roadside testing rigs now for all vehicles easy pickings on the cash front (maybe) with fixed penalty notices all over the shop that very few people will contest IMHO. Whereas going back to our LED example, say that it is actually E marked and E tested all above board, it is effectively a "sealed beam" lamp fitting (i.e. it does what it does and complies with the regulations as far as the "E" marking is concerned all day long, and no amount of "upgrading" or changing of lamps will change it's output. As Nick has stated elsewhere the E regulations concerning "lamp fittings" are just that .... for lamp fittings not the whole vehicle in it's installed state (that too has an E marking potentially, but is a different standard). That I'm sorry has to be a better more bonefide solution (obviously providing you include the other criteria of the IVA regs .... lamp wash + automatic leveling (in compliant with the ECE requirements, etc etc). Long and the short, I do not believe that just binning your old 7" halogen lamp fittings and installing 7" LED's is compliant with the regs, you need headlight wash + headlight leveling. Insurance is insurance, and if they spot a heavily modified vehicle that they feel they can wriggle out of a claim, I'm afraid they probably will try their best, and unless you can fight them in court you ain't got a leg to stand on (it ain't your money till it's in your hand in bank notes) as they could find all manor of exclusions (including those Night Breakers (or other Halfords sold "improved light output lamps" off the shelf that took your fancy) you fitted but now may have contributed to a head-on collision due to dazzling the oncoming vehicle on a winding A road because the light output is now just so much better). but either you forgot to tell them about as it was a routine lamp change or they did not list it down following your phone call as they thought that changing some headlamp bulbs are a de minimis change and you need to get a life! Each to their own, and we're all big boys to make decisions based upon the best information you had available at the time, bad stuff sometimes just happens that you never could have forseen or planned, an E-approved LED 7" headlamp on the balance or probabilities just is not one of them with a wash and automatic leveling system installed too to comply with the IVA requirements. Rob (I'm a long way from fitting headlights to my pile of bits, so I'll watch this one how it pans out for the next few months). Quote Link to comment Share on other sites More sharing options...
robertspark Posted February 16, 2015 Share Posted February 16, 2015 Wow, that was a long post, sorry, delete if its too much no offence taken need to get outside now! Quote Link to comment Share on other sites More sharing options...
need4speed Posted February 16, 2015 Share Posted February 16, 2015 At last common sense prevails.. Edit: My reply was in response to simon. Quote Link to comment Share on other sites More sharing options...
robertspark Posted February 16, 2015 Share Posted February 16, 2015 At last common sense prevails.. Edit: My reply was in response to simon. roberspark (sorry!) Quote Link to comment Share on other sites More sharing options...
need4speed Posted February 16, 2015 Share Posted February 16, 2015 No no i didnt mean it like that lol. I was still writing my reply when you posted. Quote Link to comment Share on other sites More sharing options...
Bowie69 Posted February 16, 2015 Share Posted February 16, 2015 Erm, in response to Simon, kit cars generally go through IVA! Hardly the same as a bolt-on-bit to a type approved car. Anyways, think the people for and against have probably made their mind up, thank you all for your input Quote Link to comment Share on other sites More sharing options...
robertspark Posted February 16, 2015 Share Posted February 16, 2015 Sorry feel like I killed the conversation haha. Quietest this forum has been since that post Watch the tumbleweed rolling past moment Quote Link to comment Share on other sites More sharing options...
Mo Murphy Posted February 17, 2015 Share Posted February 17, 2015 It appears we've found a minefield chaps. Quote Link to comment Share on other sites More sharing options...
V8 Freak Posted February 17, 2015 Share Posted February 17, 2015 Back to candle power..... Quote Link to comment Share on other sites More sharing options...
mmgemini Posted February 17, 2015 Share Posted February 17, 2015 For those of you that can go back to Nov/ Dec 1959..Remember the now wonder lamp from Phillips. Yep the QI later to be re-named halogen. At that time it was talked that the QI was too bright. Well soon everybody was using them. It wasn't until the double filament version cam out that you could fit the H4 into headlights. NO problem because the filament was the same as in the earlier lamp {bulb} So are these 100% brighter lamps giving a different beam pattern or is it just the gasses in the envelope, an H4 has an envelope not a bulb, that have been changed ? Quote Link to comment Share on other sites More sharing options...
elbekko Posted February 17, 2015 Share Posted February 17, 2015 For those of you that can go back to Nov/ Dec 1959..Remember the now wonder lamp from Phillips. Yep the QI later to be re-named halogen. At that time it was talked that the QI was too bright. Well soon everybody was using them. It wasn't until the double filament version cam out that you could fit the H4 into headlights. NO problem because the filament was the same as in the earlier lamp {bulb} So are these 100% brighter lamps giving a different beam pattern or is it just the gasses in the envelope, an H4 has an envelope not a bulb, that have been changed ? Osram Nightbreakers are just an H4 bulb. What's going on inside, no clue. They have a very clean cutoff (at least in my P38). Quote Link to comment Share on other sites More sharing options...
need4speed Posted February 17, 2015 Share Posted February 17, 2015 Back to candle power..... I called my inurance about that Neil. They wouldnt insure me. Not unless i could find e-marked candles.... Quote Link to comment Share on other sites More sharing options...
Simon Smith Posted February 17, 2015 Share Posted February 17, 2015 You don't always need an IVA or SVA for a kit or customised car, or at least you didn't unless the rules have changed again. If the unaltered chassis or structural shell and running gear was used you could change some body parts, including the lights no problem at all. The EEC have tried unsuccessfully to ban customisation, but as far as I am aware the UK government said no. Just a thought, if you can't legally replace your H4 units with LED's because it wasn't buil;t with them. The same rule would apply to changing sealed beams on a commercial variant to H4, as they also have different E numbers and were not originally approved for that vehicle. Minefield anyone? We sometimes have to make tractors road legal at work for the water company, and get them registered, there is no restriction whatever on whose lights we fit as long as they are E marked and conform to curent regs, we need no IVA, just a "certificate of newness" from the manufacturer or importer. Though to be fair it is a hell of a lot easier to get an Agri vehicle registered than it is a car. However I have found when dealing with any of the authorities that 90% of their staff don't know the rules themselves and always interpret them differently, which doesn't help at all. Quote Link to comment Share on other sites More sharing options...
Bowie69 Posted February 17, 2015 Share Posted February 17, 2015 Indeed Simon, but I would still say *most* go through IVA's today, or rather should. And totally agree on the 'no-one really knows' at most places, that's the problem when things are made so complicated! Quote Link to comment Share on other sites More sharing options...
Daan Posted February 17, 2015 Share Posted February 17, 2015 I think it has been mentioned here before, but the 2015 Autobiography defender comes with led headlights. It would be good to find out which lights they use and try to track these down. Certainly, if it has a land rover part number, I think you have a case of using them on any defender. After reading all the 6 pages of headlight chat, I think I am going to get myself a set of osram night breakers for my daily driver; the standard lighting on this is garbage! Daan Quote Link to comment Share on other sites More sharing options...
robertspark Posted February 18, 2015 Share Posted February 18, 2015 given this thread had sort of died a death maybe (shock / fear of non-self incrimination etc??).... Thought I'd explore the "VOSA will prosecute offenders" angle (never thought about it before not having been in trouble etc), but I was wondering what powers do the law enforcement officers have to stop a vehicle, and potentially haul it off the road for weeks whilst they carry out investigations to attempt to build a case against you of a law infringement. At the end of the day there was some fairly large sweeping statements made at one point in this discussion which was all based upon the OP question of "LED's any good?" & "anyone fitted them?" remember, IANAL and no nothing whatsoever on the subject, so this is more of a "factual review" of published guidance VOSA were replaced by DVSA in April 2014 .... but there does not seem to be much in the way of what powers of enforcement they have published that is, however lets assume for a moment that as there was a merger the old published VOSA powers are still in force and the majority of their guidance documents are still current and enforceable (at the end of the day both organisations are trying to do the same thing through a merged service with the DSA, efficiency savings and all that guff!) That being said, VOSA were pretty impressive and issued this guidance document on "Guide to Graduated Penalties and Financial Deposits", so presuming that its still current as the original document does not appear to have been replaced by the DVSA (not got round to it maybe? (efficiency savings?)) It actually is a damn good guide to what enforcement powers they have and it appears very crystal clear including what laws they rely on and when they can prevent a vehicle being driven on the road, etc. If you review pdf page 10/60, there is a very clear and short section (3.5) on Roadworthyness Offences which is probably (IMHO) what an attempted prosecution would be carried out under as most of the other elements are driver or commercial vehicle related. There is some very clear guidance of what the examiner can issue a prohibition which must be followed, and it appears to be a case "where there is a current or very imminent risk to road safety", none of which really fall into the category of "replacement headlamps" or "replacement lamps", given lets presume that the newly fitted LED headlights are both working, functioning, aligned etc, etc. However even clearer guidance is given section 10.4 Offence Penalty Levels, presuming we're going to get somewhere from a verbal warning, all the way to a court prosecution. Accepting for a moment that it's a "construction & use offence" given someone changed something they shouldn't. It appears from a quick scan of the list that on page 42/60, second item down, is listed "defective headlights" as the description of the contravention, also in the very clear and helpful list is "legislation specifying the offence" (which is Section 42 of the Road Traffic Act 1988) and even more helpful "Further details of contravention, if relevant" (which is Reg. 23(1) Road Vehicles Lighting Regs. 1989). A quick scan of these two legal elements (an act and a regulation) indicates that the Act simply says you've breached the construction and use regulations from something other than brakes, steering gear, tyres, vehicle weight, were not in control of the vehicle or using a mobile phone etc. The regulation says: "Maintenance of lamps, reflectors, rear markings and devices 23.—(1) No person shall use, or cause or permit to be used, on a road a vehicle unless every lamp, reflector, rear marking and device to which this paragraph applies is in good working order and, in the case of a lamp, clean. " Which in essence means in needs to be good working order and it's clean.... Seems like the statement that Matey from VOSA said - "fit the blessed things, just don't have an accident where we get involved as we will prosecute and your insurance will be void so you will also get a criminal prosecution form the Police; also don't get pulled into a VOSA check site as we will use it for a prosecution because we need the money..." Probably wouldn't wash as they don't seem to have the enforcement powers for issuing a penalty charge or attempting a prosecution under the, given the laws that they are reliant make no mention of E approved headlights it's more to do with are they working and clean and is there an imminent risk to road safety (which if stopped during the daytime a set of working clean headlights are not). Interesting read of the MOT manual (section 1.7 & 1.8), makes only a cursory remark that European headlamps may carry an E-marking (but it's not a fail if it doesn't), but you need the headlight wash (fail if they don't or it doesn't work) and automatic leveling for LED's and HID's (although the benefit of the doubt should be given if unable to determine readily that it's functioning), and obviously the aim needs to be correct + the beam pattern. Seems it would be an interesting argument to have to be given a penalty charge for the use of E-marked LED's really (with associated headlamp wash and automatic leveling installed too)..... problem is most people just pay the penalty charge at the discount rate (which if VOSA attempted would be £50 discount rate, or £75 after 28 days) and don't contest the charge as the balk at the intimidating letters and the time for due process plus exchanges of information all whilst being intimidated in correspondence to pay the fixed penalty. It's still a modification from factory standard so would need insurance disclosure but for the right fee cannot see why it would be an uninsurable risk. (heard of someone getting insurance for his 17 year old son, newly qualified driver for a veyron which was about a £16-£20K premium before adding his son on, don't know what the final cost on that one would have been...) Hopefully there is enough referenced fact and less opinion in this one. Rob Quote Link to comment Share on other sites More sharing options...
reb78 Posted February 18, 2015 Share Posted February 18, 2015 You say they need headlamp levelling and washers, but the document says: 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. That is 'MAY' be fitted, so that, to me, does not read that it is compulsory to fit self levelling and washers, but that they must work if they are fitted? All of these documents are open to too much interpretation to be of any use! (not a criticism of your efforts to explain it Robert, just that it is still clear as mud). Quote Link to comment Share on other sites More sharing options...
krissvdh Posted February 18, 2015 Share Posted February 18, 2015 Good posts Robert, well referenced posts. The way the headlight wash and self levelling reads (to me) is that the function of both is only checked if they are present. It does not determine if they should or should not be fitted. This is obviously open to the testers interpretation. LR have set precedent by fitting LED headlights to the limited edition spec vehicle. Seeing as it's unlikely to have obtained separate type approval, C&U regs etc one could argue that vehicles of this type could be retro fitted with LED lamps. As far as I'm aware headlamp levelling (operated from the roller switch on the dash) is fitted to 07> Defenders depending on trim level. Allowing for the unlikely possibility that the limited edition vehicles have self levelling headlights or suspension any department or operator failing an 07> vehicle for having LED headlamps would be opening Land Rover up for a hell of a lawsuit as one could argue that they are 'a factory option'. Interesting topic, I was looking at some J.W. Speaker LED headlights at last years LRO show. Kris Quote Link to comment Share on other sites More sharing options...
Davedef90 Posted February 23, 2015 Share Posted February 23, 2015 I think it has been mentioned here before, but the 2015 Autobiography defender comes with led headlights. It would be good to find out which lights they use and try to track these down. Certainly, if it has a land rover part number, I think you have a case of using them on any defender. After reading all the 6 pages of headlight chat, I think I am going to get myself a set of osram night breakers for my daily driver; the standard lighting on this is garbage! Daan I'm sure the run out models are using Nolden headlights. Have a look at the Def2 forum. LOTS of interesting debate over the different brands. Nolden, JWSpeaker and Trucklite. Pays your money, takes your chances Quote Link to comment Share on other sites More sharing options...
Daan Posted February 23, 2015 Share Posted February 23, 2015 I am afraid plenty of hear say on that forum, rather than factual information on e-marking etc. Interesting to know the brand that land rover use. Do they fit it with levellers and washers? Daan Quote Link to comment Share on other sites More sharing options...
Davedef90 Posted February 26, 2015 Share Posted February 26, 2015 As I said LR are using NOLDEN lights. That is clear. Peole have even quoted LR part numbers. Quote Link to comment Share on other sites More sharing options...
wanger Posted February 26, 2015 Share Posted February 26, 2015 Jason...any news on these please Quote Link to comment Share on other sites More sharing options...
Guest Posted February 26, 2015 Share Posted February 26, 2015 I have not chased it as most of the factories take a couple of weeks off for the new year celebrations. I will be back on it next week and with a fair wind I will have something by the end of next week. Jason. Quote Link to comment Share on other sites More sharing options...
wanger Posted February 28, 2015 Share Posted February 28, 2015 great thankyou for the update Quote Link to comment Share on other sites More sharing options...
Guest Posted March 5, 2015 Share Posted March 5, 2015 Just a quick update on this to say that things are progressing well and I hope to have some very good news by the end of this week and will start the group buy hopefully next week. There was also a clarification letter on the law, and a letter from the DfT/VOSA stating that as long as they are under 2000 lumin then no self leveling or wash was required as they were judged as a like for like replacement for the existing units hence LR can use then without any further type approval as the unit it's self meets EU standards. Jason. Quote Link to comment Share on other sites More sharing options...
Recommended Posts
Join the conversation
You can post now and register later. If you have an account, sign in now to post with your account.
Note: Your post will require moderator approval before it will be visible.