Official DoT responce to HID's

[Mike M]

All,

I like you have been bewildered by everyone's interpretation of the forthcoming MOT changes so I approached the DVLA directly as per below:

"I would appreciate it if you could advise me on the following:

I have owned a 1994 Porsche 911, 993 C2 model for 6 or 7 years now.
Although my vehicle is as it left the factory, the first things I did upon
purchase was upgrade the dipped headlights with a retro-fit HID system as
the standard system is appalling and a well-documented issue with this
model due to its dangerously low illumination level.

However I have been made aware that the 2012 MOT changes will affect cars that have had after-market HID conversions and must have washers and auto levelling systems to compliment. I have also been made aware that there may be some possible exclusions to this, being cars with limited occupancy ability, limited luggage space and sports suspension as the effect on beam displacement is minimum due to the afore mentioned. I would appreciate it if you could clarify exactly where I stand as I do not want to sit an MOT to find it fails on this as I would rather have the system reverted back to manufacturers standard before the fact and never drive it at night again!

The 911 sits 2 adults in the front and can fit 2 small children in the rear,
has a small luggage compartment at the front and obviously has sports
suspension as standard. My vehicle has headlight washers but does not have auto levelling.

Your assistance would be greatly appreciated and you may get very similar enquiries from concerned 993 owners over the coming months."

This was passed to the DOT who replied:

"Thank you for your email enquiry dated 14th March 2012, concerning HID
headlights.

The inclusion of an inspection of self levelling etc with HID headlamps
becomes part of the test later this year (approx Spring). As it is quite
difficult to determine operation and the requirement (which depends on
light output) to fit self-levelling etc the MOT only includes an
inspection of those devices which are fitted and can be readily recognised.
There is no reason for rejection of a system being missing so a vehicle
could not fail for this reason and if the Nominated Tester is unable to
readily determine whether the systems are required then it would be
reasonable to pass and advise.

It may be beneficial to view the on line MOT Inspection Manual. The
information that you require is detailed in Section 1.7. Please find a
link through to this below:

http://www.transportoffice.gov.uk/crt/doitonline/bl/mottestingmanualsandguides/mottestingmanualsandguides.htm

I hope this information has assisted you with your enquiry, but if you have
any further questions please do not hesitate to contact us again."

Hope this helps clarify things; however I believe it best to get information straight from the horse's mouth.

Cheers

Mike

 

[scaramanga]

Thank you for the post above. My interpretation of the response is that HID upgrades (without self-levelling systems) should not result in MOT failure. Is that fair ? Really glad someone has clarified the position - hopefully this will end much of the speculation. Much appreciated!

 

[gm997_1]

Thx for going public with that, Mike It leaves me wondering if the tester then has to test the standard headlamp washers (once he notes that the the car has HIDs from the headlight test), which didn't used to need testing. Presumably he should. Because I imagine these are gunged up at the pump end in quite a few cases due to coagulation of the various additives in the bottom of the washer tank, therefore causing a fail [] Graeme

 

[tallmat]

That's a surprisingly helpful reply from DoT. Well done for posing the question, and for it reaching someone who's reply is a proper answer.

 

[Mark Elder]

Well done - think I'll print this out and take it along to my (admittedly very classic-friendly) MOT man when I go in August. Amazed DLVA have time to reply individually. Must be what the tax disc pays for![]

 

[clyde]

Damn blast, I thought that this piece of legislation would have got rid of all those annoying cars fitted with after-market HIDs. The only thing that's worse than them blinding me when coming towards me is when they're sitting behind and blinding me in all three mirrors. Although adjusting the door mirrors so the light reflects back and blinds them is quite a laugh. Sounds like there's still a bit of discretion on the part of the tester though, so hopefully all is not lost [8|]

 

[harry]

Yeah, I especially hate 4X4 with these - they should be banned on bigger vehicles as it just blinds oncoming traffic []

 

[hanhams81]

Thank you Mike M. I am relieved I will not have to throw away my HIDs. Common sense does exist after all. Cheers Hanhams81

 

[clyde]

Notwithstanding the above reply from the DfT regarding mot testing, don't forget that there is still something of a question in respect of the legalities of retro-fitting HIDs to cars not originally fitted with them. The general concensus of the DfT seems to be that as the Road Vehicle Lighting Regulations 1989 does not specifically mention HID/Gas Discharge/Xenon headlamps that they are not permitted in the UK. However, new cars with them are OK as they have a European type approval, which will include the HIDs and must be accepted when registering the car here. MoT testers test what they are told to test and ignore what they are not; it's a bit like illegal number plates, which until recently were not part of the test and therefore a car could not fail just because the characters were not of the correct size, font or spacing but despite this they were still illegal. Out of curiosity, has anyone with retro HIDs fitted asked their insurers whether they would consider them to be a material change?

 

[gm997_1]

But for our cars, they're already specced up to take HIDs (lenses, reflectors, headlamp wash) from the factory, and we know it's not necessary to retro-fit self-levelling suspension due to existing stiff Sports suspension, or to rewire them, so it's unlikely to be classed as a material change. Certainly an alteration to original spec, yes, but not one that is materially different. To me it's the same as fitting 18" genuine Porsche wheels with the correct ET and tyres - the car is specced to take it already so wouldn't be classed as a material change. But, as they say, there's more than one way to skin a cat ...

 

[clyde]

ORIGINAL: graeme But for our cars, they're already specced up to take HIDs (lenses, reflectors, headlamp wash) from the factory, and we know it's not necessary to retro-fit self-levelling suspension due to existing stiff Sports suspension, or to rewire them,

That being the case, why are those 993s fitted with Xenon lights from the factory fitted with self levelling equipment Graeme?

ORIGINAL: graeme To me it's the same as fitting 18" genuine Porsche wheels with the correct ET and tyres - the car is specced to take it already so wouldn't be classed as a material change.

It's got nothing to do with whether or not the wheels (or HIDs) are suitable for the car or vice versa, it's all about risk as far as insurers are concerned. For example, my son has just bought a 987 fitted 19" Carerra S wheels as a factory option - when he declared this to his insurer they placed an additional charge on the policy. It's all about whether the insurer considers the modification to be an additional risk, whether this is wheel theft or an indication of how the insurer thinks the car may be driven. Or whether they consider the driver of the car fitted with after-market HIDs was responsiblie for an accident as he or she blinded the driver of the car coming the other way????

 

[Mark Elder]

Clyde, Wow, seems to me your son's insurance company is close to to taking the p. They are probably really charging for the mod to the policy rather than the mod to the car. But I accept the general point that insurance companies behaving the way they do they have rather brought upon themselves a deluge of calls to declare each time wax is added to the paintwork or a stone chip is filled in. Think I'll call my insurance company every time I change brand of washer fluid as I now don't use Porsche own![]

 

[John Maddox]

You do need to be careful though with Insurance Companies - look at what happened to people who informed them about fitting winter tyres- initially the industry increased premiums until common sense prevailed !! If you modify from standard spec. then inform them - especially if it changes performance or look of the vehicle. What amazes me is that if you increased the performance of brakes or grip through bigger tyres I have never heard of anyone having premiums reduced.

 

[38F3E1]

Most of the problems with aftermarket HIDs are not about self levelling but about the fact the lights are fitted behind standard lenses which are not made for HID light and scatter the light incorrectly. Each lense is EU marked to say what light source it is made for and it is technically illegal to mismatch lense and light source but that's not part of the MOT test so gets ignored. The Porsche unit is a completely matched setup. Ian.

 

[pse_SC]

This is not correct, surely. The blinding factory fitted lights on posers’ 4x4s and other ‘bling’ vehicles is excessive[]; surely they must have been approved/have matching bulbs/lenses? As their car bounces along you can get extreme flashes which can also be misconstrued[8|].

 

[38F3E1]

The lenses (and lamp unit e.g. internal reflector shape) for tungstan, halogen and HID are a different design because the light created by the bulb is a different shape and spectrum. There are specific EU marks for the lenses/lamp unit C Low (dip) beam headlamp, tungsten filament R High (main) beam headlamp or driving lamp, tungsten filament CR Low/high (dip/main) beam headlamp, tungsten filament HC Low (dip) beam headlamp, halogen HR High (main) beam headlamp or driving lamp, halogen HCR Low/high (dip/main) beam headlamp, halogen DC Low (dip) beam headlamp, gas discharge (HID Xenon) DR High (main) beam headlamp or driving lamp, gas discharge (HID Xenon) DCR Low/high (dip/main) beam headlamp, gas discharge (HID Xenon) Here is a bit of blurb << These markings may occur in variant forms. For instance, HCR may or may not be surrounded by a box, and may occur as HC/R. Markings may also occur together. For example, a front lamp cluster that incorporates a low beam headlamp and a high beam headlamp, each with its own halogen bulb and reflector, would be marked HCHR, while a front lamp cluster incporporating a Xenon HID low beam headlamp and a halogen high beam would be marked DCHR. >> Having mismatched bulb and lense/lamp unit is a bad start. Faulty/missing levelling, etc make things worse. In places like Germany that are much stricter than the UK this would be an automatic TUV fail. Ian.

 

[D Ward]

ORIGINAL: clyde

ORIGINAL: graeme But for our cars, they're already specced up to take HIDs (lenses, reflectors, headlamp wash) from the factory, and we know it's not necessary to retro-fit self-levelling suspension due to existing stiff Sports suspension, or to rewire tham,

That being the case, why are those 993s fitted with Xenon lights from the factory fitted with self levelling equipment Graeme?

ORIGINAL: graeme To me it's the same as fitting 18" genuine Porsche wheels with the correct ET and tyres - the car is specced to take it already so wouldn't be classed as a material change.

Early 993s fitted with litronic headlights Did not have self levelling Clyde ?

 

[gm997_1]

ORIGINAL: clyde quote: ORIGINAL: graeme But for our cars, they're already specced up to take HIDs (lenses, reflectors, headlamp wash) from the factory, and we know it's not necessary to retro-fit self-levelling suspension due to existing stiff Sports suspension, or to rewire tham, That being the case, why are those 993s fitted with Xenon lights from the factory fitted with self levelling equipment Graeme? quote: ORIGINAL: graeme To me it's the same as fitting 18" genuine Porsche wheels with the correct ET and tyres - the car is specced to take it already so wouldn't be classed as a material change.

Clyde, it depends on which vintage you're looking at as not all MYs from 95-98 had factory-fit self-levelling together with HIDs. Strictly speaking, on a 993, self-levelling is overkill, but Porsche followed suit later on and added it to be in line with the accepted practice in the motor industry. But that is getting away from the point. The point is that the MOT test is to see whether or not the headlight (HID) beam deviates beyond certain parameters when it is switched on, that's all. Doesn't check for dazzle, doesn't check when laden, as you know. But on a 993, stiff Sports suspension ensures that the beams are absolutely fine in both these scenarios and go well beyond the MOT requirement. When you bring other brands and non-sports cars into the equation, that's a different story, as they're not all pre-specced to take aftermarket HID add-ons. Insurance companies are invariably inconsistent too. So when one company is quite happy to accept 19" wheels in place of 18s, without changing the premium, another one won't even accept professionally heatproof painted calipers inplace of non painted calipers. From an insurance angle, how we define the change to the vehicle is largely immaterial; they see it as an alteration to original spec. They individually will load that alteration in terms of premium, or not. Here's where factors come in such as more attractive to steal, more difficult to control, wild increase in speed, effect on integrity of vehicle, etc etc, up to the point where the car is insurable or not. What fun it's all going to be after April 2012 (MOT change) when all these new permutations come in ...[&:]