LED Lighting Conversions

October 2020:

A frequently raised topic, with people very keen on changing external lighting to LED but you need to be aware that it is a very confused picture as regards legality with various light units having different dates as to when it can and can't be done. You should always advise your insurance company, if not enquire of them before spending any money, or you could be at risk of invalidating your insurance. It's your choice and your risk. Note that there are no such limitations on converting internal lighting to LED.

I recently came across stop/tail lights suitable for the MGB using a different construction to those I had seen before, CE and ROHS marked, so I thought one was worth a punt to see if it overcame the problems with other types I had tried. Note the CE and ROHS markings are nothing to do with whether they are legal on your vehicle or not. In fact they did overcome all the problems I had experienced with other types, and would appear to be a useful upgrade. But ...

I asked my insurance company about them and their response was "I have checked this for you and advise that as long as the replacement bulbs are road legal, and would allow your vehicle to pass an MOT, they are fine to be fitted to your vehicle." Which doesn't actually help me at all, unlike a previous enquiry about LED headlights where the response was a flat 'No'.

The vendor - Classic Car LEDs - gave me a long but useful and interesting response which I reproduce in full below. That includes a statement from the FBHVC which includes a link to their investigations also reproduced in full below.

The most important points are:

  • Whilst today LEDs are tested and approved for use in specified lamp assemblies none bear the approval permitting them to be used in e/E marked lamps intended to employ incandescent bulbs.
  • An MOT pass is at the discretion of the examiner but this does not make them road legal.
  • The Road Vehicle Lighting Act (RVLA) gives some exemption to vehicles of certain ages but as the act does not specifically mention LEDs it cannot be inferred by their absence that they are legal for road use despite what others may state.
  • LEDs, to gain homologation, need to be approved in every single light unit they could be fitted to. As you can imagine, this is an impossible task.
  • Department for Transport - "The guidance provided is based on the requirements of The Road Vehicle Lighting Regulations and all vehicles must comply when used on the road, ultimately interpretation of law is the sole prerogative of the courts."
  • The regulations include a requirement applicable to all lamps that they shall not cause undue dazzle or discomfort to other persons using the road. This should be borne in mind whenever a lamp is made to be brighter than it was originally designed to be.
  • The regulations quote minimum wattages for certain lamps. These minimum wattage limits were undoubtedly included originally to ensure adequate brightness of the lamps in question but now they provide a barrier to the use of LEDs. This arises because of the greater efficiency of LEDs, i.e. more light from fewer watts, the result being that the LEDs are of too low a wattage to comply with the regulations even though the actual light output may be entirely adequate.
Lamps where the use of LEDs is legal subject to conditions:
  • Front Position Lamps. (Side lamps). Vehicles first registered before 1st January 1972: LED light sources in the original lamps are compliant.
  • Rear Position Lamps. (Tail lamps). Vehicles first registered before 1st January 1974: LED light sources in the original lamps are compliant.
  • Rear Registration Plate Lamps. Vehicles first registered before 1st April 1986: LED light sources in the original lamps are compliant.
  • Stop lamps. Vehicles first registered before 1st January 1971: LED light sources in the original lamps are compliant.
Lamps where the use of LEDs is not legal:
  • Stop lamps. Vehicles first registered after 1st January 1971: LED light sources in the original lamps are non-compliant. This is because LEDs will not meet the minimum wattages specified in the regulations.
  • Direction Indicators. (flashing type). LED light sources in the original lamps are non-compliant. This is because LEDs will not meet the minimum wattages specified in the regulations.
  • Headlamps. LED light sources in the original lamps are generally non-compliant. This is because LEDs will not meet the minimum wattages specified in the regulations. However, in some particular cases it may be possible to locate LED light sources of compliant wattage. (Note that these will sake the same current and get as hot incandescent. As low-current LED headlights come with heat sinks and a warning that wiring must be kept away from them, this additional heat inside the headlamp bowls used on MGB and similar is likely to cause wiring damage.)
From 22nd March 2021 halogen to LED and HID conversions on cars first used before 1st April 1986 are legal.

For optional lamps such as after-market fog, spot or DRL there are no wattage requirements meaning LEDs can be used, subject to not causing "undue dazzle or discomfort to other persons using the road".

The Classic Car LEDs response in full (passages in bold are my emphasis):

Regarding insurance, we are finding from customer feedback that many insurers are beginning to accept LED upgrades that pass an MOT as an acceptable safety upgrade. We do however recommend that you check with them though. Our full response on this is as follows:

The question of external vehicle lighting LED upgrades and legality, particularly headlights, is a complex issue which is not made any clearer by the fact the regulations stem from the RVLA.

We discuss legality with a number of organisations and individuals on a regular basis, such as EU commissions , MOT Inspectors, Insurers and many Classic Magazine writers who thoroughly research the matters with the DfT and other regulatory bodies.

Generally LED conversions are not 100% road legal for all external bulbs, though ours all show the correct output and beam patterns (which many don't) so are not normally picked up by MOT testing and don't give glare to other road users. Many insurers are now becoming tolerant of them though and allowing the use of good quality LEDs such as ours, particularly on classics, as they are CE marked and they see them as a big safety improvement. Changing to LED for external lighting is a vehicle modification that you need to advise your insurer of as with any other modification from factory specification.

The changes made in May 2018 to UK MOT law banned HID conversion (not LED) for headlamps and some inspectors are treating this as LED too though many customers are reporting passes since the change was made. We will not guarantee a pass though as the pass is at the discretion of the examiner. Other fittings such as sidelights, brake lights and indicators may be OK for MOT purposes but again this is at the discretion of the examiner and this does not make them road legal. A number of clubs we work with on regular basis have contacted their local MOT stations and have been advised that LED upgrades are fine in their view as long as the tests results are satisfactory. A small proportion have advised they would not pass a vehicle fitted with LED conversions.

This situation was raised with the FBHVC for their comment and they reported: The Federation has covered the general topic of using LED light sources in historic vehicles in an article published in the FBHVC Newsletter, edition 5/2017. This is available on the Federation website (https://www.fbhvc.co.uk/newsletter-archive). From this you will see that the use of LED light sources in headlamps is very likely to be in contravention of the regulations. With regard to the 2018 change to the MOT Regulations the relevant amendment, which itself reflected already existing DfT advice, applied specifically to HID conversions. As you know HID is a different technology to LED and in our opinion to apply that requirement to lamps with LED light sources would be incorrect.

One of the problems here is that there is yet to be a test case with the courts to prompt definitive legislation on the use of LED bulbs being retrofitted to classic vehicle headlamps. Another is interpretation by MOT testers of the current lighting regulations. The Editor of one of our local club magazines own experience is that in a ‘straw poll’ of four local MOT stations, including testers who had undertaken recent training, is that they all passed classic cars fitted with LED headlight (and sidelight) bulbs, provided the beam pattern was correct, did not dazzle, were the correct colour etc. This of course is not conclusive but seems to indicate that the interpretation of the regulations is inconsistent and also, perhaps, that the technology is moving faster than the law.

The Road Vehicle Lighting Act (RVLA) gives some exemption to vehicles of certain ages but as the act does not specifically mention LEDs it cannot be inferred by their absence that they are legal for road use despite what others may state. As a result we are cautious and sell all our external LEDs on the basis of "Off Road Use" only.

It's a grey area between safety and legality that we leave to customer choice. Our Terms and Conditions which are linked to on every page on our website and email footer cover this. Internal LED conversions are 100% legal and are not covered by the RVLA.

External LED conversion is an area where the law has not kept pace with technology. However there is the battle with the large vehicle manufacturers and the influence they have with the authorities due to tax revenues, who do not like their vehicles being open to the aftermarket. At present, and we believe unfairly, LEDs, to gain homologation, need to be approved in every single light unit they could be fitted to. As you can imagine, this is an impossible task.

The wattage referred to in the RVLA actually refers to the light output, not the load. It's another reason the legislation needs to be revisited and updated as it is seriously behind where the industry is with technology.

We've been looking at this for a couple of years. The result of our research and correspondence received from a number of sources is as follows:

LEDs used for headlamps as LED modules for example, are always approved in combination with the complete headlamp (Regulations Nos. 112, 113 and 123). According to the Department of Transport (DfT), the Road Vehicles Lighting Regulations 1989 do not mention more recent developments in alternative light sources at all, such as HIDs (or LEDs) and, according to the DfT, this means that, strictly, such light sources are not allowed under British law. Many people presume that, because something is not mentioned, it is allowed, which is incorrect. The date exemptions shown in Schedule 4 only apply to technology that was available at that time, being filament bulbs. We've also checked with United Nations Economic Commission for Europe and they have advised that no type approval currently exists for any LED module in the EU despite what is claimed by some as mentioned above. There are working groups within UNECE looking at retrofit LEDs but no decisions have yet been made.

The E mark approval shown on many units coming out of Asia often only grants type approval to that particular LED bulb in accordance with UN Regulation No.10 Uniform provisions concerning the approval of vehicles with regard to electromagnetic compatibility. IDIADA concluded that the LED bulb does not cause electromagnetic interference and granted the type approval accordingly, with the marking R10-05, i.e. UN Regulation No.10, revision 5 (latest version). This does not make it road legal but is just an E Mark to state it will not cause electromagnetic interference. To ascertain what the E mark is for, you need to ask for the certificate of approval which will state the section of the regulations that the unit is approved under. In a lot of cases they will not provide it.

As far as we are aware, this is the full legal position for external vehicle LEDs which is why we state "off road use only". We are continuing to find an approval route but it will not be quick unless the various bodies decide to look carefully at the excellent products now available and the fact that the beam patterns and lighting are often better than older filament fittings and provide a safer motoring experience.

End of Classic Car LEDs response

The FBHVC article:

Regulatory Position on the Use of LED Light Sources in Historic Vehicles

The 1970s saw the immergence of lamps approved to European standards. There were two parallel sets of standards, normally technically identical but emanating from different organisations. These were ECE Regulations and EEC Directives, lamps approved to the former were identified by an approval number preceded by a capital ‘E’ whilst those approved to the latter bore a similar mark preceded by a lower case ‘e’. These are commonly referred to as ‘e/E marks’. The testing required to gain such an approval for a lamp was far more scientific than anything that had gone before and included measuring actual light output across a standard grid. Repetition of this performance can only be guaranteed by use of bulbs meeting precise standards and for this reason a similar approval regime exists for bulbs and e/E marked lamps on vehicles first used after 1st January 1986 are only permitted to be fitted with approved, and e/E marked, bulbs. Whilst today LEDs are tested and approved for use in specified lamp assemblies none bear the approval permitting them to be used in e/E marked lamps intended to employ incandescent bulbs.

Background
The use of LED light sources has been of interest to the historic vehicle community for as long as LEDs have been readily available and not surprisingly many articles have been written on the subject in both club magazines and in the specialist press. Unfortunately, not all of the information provided has been accurate and FBHVC felt it should research the subject to enable the provision of definitive guidance to its members.

In addition to research by the FBHVC Legislation Committee an opinion was also sought from Department for Transport and the Committee were gratified to find their conclusions confirmed. However, we should repeat a warning from the DfT reply - "The guidance provided is based on the requirements of The Road Vehicle Lighting Regulations and all vehicles must comply when used on the road, ultimately interpretation of law is the sole prerogative of the courts."

As the title implies this article relates solely to the regulations surrounding the use of LEDs but nevertheless a brief explanation of what we mean by LED and the reason why their use can be beneficial might not come amiss. LED is an abbreviation of light emitting diode and their advantage stems from the fact that they do not generate as much heat as a conventional incandescent bulb. Thus, for a given electrical power the light output is much higher, or conversely a given light output can be achieved from a lower electrical power. This latter characteristic is of great value in early vehicles with marginal generator output.

Unfortunately, the relevant regulations are quite complex and there is no simple overall yes or no answer to the question "is it legal to use LEDs in the existing lamps on my historic vehicle?" The situation is different for different lamps and also for different dates of first registration of the vehicle in question. This article will explain the background before summarising the conclusions at the end.

There is no regulation that specifically prohibits the use of LEDs in lamps first used prior to the e/E marking requirements, although there is a requirement for e/E marked lamps fitted to a vehicle first used on or after 1st April 1986 to be fitted with e/E marked bulbs. (see above)

The applicable date varies for different lamps but it should be noted that these dates are such that vehicles from the end of our period will be affected.

The regulations also include a requirement applicable to all lamps that they shall not cause undue dazzle or discomfort to other persons using the road. This should be borne in mind whenever a lamp is made to be brighter than it was originally designed to be. With particular reference to headlamps, a light source of a different type and in consequence of different physical size and shape is very unlikely to work correctly with the optical design of the lamp and the risk of causing undue dazzle or discomfort becomes a very real one.

Another complicating factor is that the regulations quote minimum wattages for certain lamps. For dip-beam headlamps these range from 10W for small motorcycles to 30W for four or more wheeled vehicles and similarly 15W to 30W for main beam headlamps. Stop lamps on vehicles first used after 1st January 1971 and all direction indicators require a minimum of 15W. These minimum wattage limits were undoubtedly included originally to ensure adequate brightness of the lamps in question but now they provide a barrier to the use of LEDs. This arises because of the greater efficiency of LEDs, i.e. more light from fewer watts, the result being that the LEDs are of too low a wattage to comply with the regulations even though the actual light output may be entirely adequate.

Conclusions
Lamps where the use of LEDs is legal subject to the conditions noted earlier:

  • Front Position Lamps. (Side lamps). Vehicles first registered before 1st January 1972: LED light sources in the original lamps are compliant.
  • Rear Position Lamps. (Tail lamps). Vehicles first registered before 1st January 1974: LED light sources in the original lamps are compliant.
  • Rear Registration Plate Lamps. Vehicles first registered before 1st April 1986: LED light sources in the original lamps are compliant.
  • Stop lamps. Vehicles first registered before 1st January 1971: LED light sources in the original lamps are compliant.

Lamps where the use of LEDs is not legal:

  • Stop lamps. Vehicles first registered after 1st January 1971: LED light sources in the original lamps are non-compliant. This is because LEDs will not meet the minimum wattages specified in the regulations.
  • Direction Indicators. (flashing type). LED light sources in the original lamps are non-compliant. This is because LEDs will not meet the minimum wattages specified in the regulations.
  • Headlamps. LED light sources in the original lamps are generally non-compliant. This is because LEDs will not meet the minimum wattages specified in the regulations. However, in some particular cases it may be possible to locate LED light sources of compliant wattage.

From 22nd March 2021 halogen to LED and HID conversions on cars first used before 1st April 1986 are legal.

The Road Vehicle Lighting Regulations, in addition to specifying which lamps are obligatory and the provisions they are required to meet, also permit the use of additional lamps, which are referred to as optional. These lamps are required to meet some but not all of the provisions specified for obligatory lamps with the result that there are no wattage requirements for optional headlamps, either dip or main beam.

End of FBHVC article