Headlamps on imported motorhomes

[Guest Derek Uzzell]

In Response (12) to my "Driving-lights in Europe" posting of 24/02/2005 I said I had written to the Department for Transport for guidance on what makes a headlamp "approved" on an imported vehicle. This was the text of my letter: "I am in the process of purchasing from Germany a new motorcaravan that I shall be importing into the UK. I have a copy of the DfT's advisory booklet (P15 Revs August 2003) that gives guidance on the process involved. Within Part 2.6 (Modifications necessary for use in Britain) on page 11 of the booklet, in the Section headed "Left hand traffic", there is the statement: "Headlamps will need to be replaced or adjusted to produce the required dipped beam for left-hand traffic. The alignment requirements must be met without the use of masks, beam converters or adapters unless they are an integral part of an approved headlamp." What I would like, please, are definitions of " the required dipped beam for left-hand traffic", "The alignment requirements" and "an approved headlight". Historically, the light emitted from a vehicle headlight in dipped mode was normally controlled directionally by the headlight's outer lens. When dipped, the lens of a 'left-hand traffic' headlight caused the light to be deflected downwards with the rightmost part of the beam being 'cut off' to avoid the possibility of dazzling oncoming traffic: whereas the lens of a 'right-hand traffic' headlight also deflected the dipped beam downwards but truncated the leftmost part of the beam. When a vehicle was used temporarily in a country that drove on the opposite side of the road (eg. when a UK-norm vehicle was driven in France) all that could be done to prevent consequential light-dazzle was to block out or deflect the higher leftmost part of the dipped beam (in the case of left-hand traffic vehicles) by affixing a mask or beam-converter to the lens. Vice versa (eg. 'Continental' European vehicles entering the UK), similar light blocking/deflecting procedures were necessary to modify the higher rightmost portion of the dipped beam. More recently the design of vehicle headlights has changed, with light output controlled not by an outer lens but by precisely shaped reflectors within the light-unit itself, and the lens has become a clear cover for weather-protection only. Sometimes manufacturers of such light-units provide the facility to adjust the bulb position (often by rotating the bulb-holder) so that the dipped beam's pattern can be altered for 'opposite-hand traffic' driving. This adjustment normally does not produce a traditional pattern but results in all the light being deflected downwards symmetrically. However, a company that specialises in importing left-hand drive motorcaravans from Continental Europe on behalf of UK buyers has told me it is quite often possible to adjust the dipped-beam component of a modern headlight to obtain a 'flat' symmetrical dipped pattern. This is despite the maker of the headlight having made no dedicated provision to perform that function. I have studied the HMSO website carrying Road Vehicles Lighting Regulations 1989 (I assume these regulations have not been superseded?) and I can find no guidance on what defines "the required dipped beam for left-hand traffic" or "The alignment requirements" referred to in the DfT's booklet. Clearly a traditional 'right-hand traffic' headlight that has a dipped-beam high rightmost element will not be acceptable, but does a 'left-hand traffic' headlight need to have a high leftmost element with rightmost cut-off to its dipped-beam pattern in the time-honoured fashion, or is a symmetrical dipped-beam pattern equally permissible? Regarding the "approved headlamp" reference, is this in fact the sole arbiter as to whether or not a headlamp is deemed appropriate for UK left-hand traffic use? Headlamp lenses used to be marked with a sideways-pointing arrow showing their 'traffic side' suitability: thus a left-hand traffic headlamp lens had a left-pointing arrow and a right-hand traffic headlamp lens had a right-pointing arrow. (I understand that some lenses carried both left- and right-pointing arrows indicating suitability for left- or right-hand traffic conditions. However, I don't know if this meant the headlamp produced a symmetrical dipped beam pattern or whether the headlight had a special adjustment facility incorporated.) I believe the reflector part of modern 'clear cover' headlights is similarly arrow-mark labelled. So, does an "approved headlamp" for left-hand traffic usage have to be marked with a left-pointing arrow (either a single arrow or as one of a pair of left- and right-pointing arrows)? If not, what makes a headlamp "approved" please? That was the last of my questions, but here are some observations... Seemingly, there is a divergence between the headlamp requirements for newly imported vehicles and lighting rules relating to our MOT test. UK importation regulations prohibit use of masks or beam converters to produce a left-hand traffic dipped beam pattern, whereas the MOT test permits them (or so all the MOT testing stations I have consulted have advised me). This definitely leads to confusion within the motorcaravan fraternity, including motorhome dealerships. At a recent trade show, the majority of second-hand left-hand drive motorcaravans being offered for sale had adhesive beam converters on their original 'right-hand traffic' headlamps. All the vendors claimed this arrangement was legal "because it would pass the MOT test". UK buyers of LHD motorhomes imported from Continental Europe usually purchase these vehicles because most of their driving is done outside Britain. Hence the original right-hand traffic headlamps (and a km/h-priority speedometer) are advantageous for such people for most of the time the vehicle is being used. Given a choice, I am sure these motorcaravanners would prefer to retain the original headlamps and mask (or convert) the dipped-beam pattern for the relatively short periods that the motorhome is driven in the UK. Even if masks/converters were not employed, all LHD motorhomes imported from Continental Europe have a headlamp-levelling dashboard control, so their right-hand traffic headlights can easily be adjusted well downwards to prevent dazzle. It is sometimes suggested that owners of imported LHD motorhomes should swap headlamps dependent on which traffic-side of the road they intend to drive. Besides the impracticality of such advice, it seems to me that, if all UK-registered vehicles must have "approved" left-hand traffic headlights, changing them to "unapproved" right-hand traffic lights makes the vehicle illegal in the UK, hence illegal everywhere in the Eurozone. This may be regulation hair-splitting but, if my argument is valid, it seems that the owner of a UK-registered vehicle can have a spare set of right-hand traffic headlamps, ideal for Continental European travel, but can't use them legally anywhere. There is a Monty Python-esque element to vehicle headlamp regulations within the Eurozone in my opinion. As a regular traveller to Continental Europe, I have always religiously masked my UK-registered vehicles' headlamps before going abroad, removing the masks immediately prior to re-entering the UK. Long hours spent on outgoing ferry embarkation car-parks have shown many UK drivers fitting masks or beam-converters to their vehicles' headlights (sometimes on the wrong side of the light-unit!) but, in over 20 years, I have never seen masks or converters on the headlamps of Continental European vehicles incoming to the UK. Such items are available in on-board ferry shops, but their sole market appears to be confined to imported LHD UK-registered motorcaravans. At one stage I thought our laws might have altered, but the police confirmed that the headlights of LHD vehicles visiting the UK must still conform to our rules. "But it's not a hot policing issue," I was informed. Near my home there is a VIA road-side check-point where the inspectors told me they never looked for 'wrong' headlights on foreign vehicles, being primarily interested in whether all the lights worked rather than unmodified dipped-beam patterns. It is a mite different abroad, where naked headlights on a RHD vehicle make it a legitimate sitting-target for an impromptu police inspection. The wonderfully perverse world of Eurozone motoring!" Mr Mike Lowe, Senior Engineer at the DfT's Transport Technology and Standards Section, replied as follows: "Thank you for your letter concerning headlamps for left and right hand traffic for your motorcaravan. It will be easiest if I explain the law in a (hopefully) logical way and in the process I will answer your many questions. I will say to you first that the law is not perfect and does not really cater for a scenario where one registers a vehicle in the UK but uses it mainly overseas. The country where a vehicle is registered determines the type of headlamp that must be fitted. There is a clear distinction between the headlamp required to be fitted to enable registration of a vehicle in a particular country, and the temporary modifications necessary to allow passage as a tourist in another country. You have commented on the requirements in the MOT test. The MOT is a basic roadworthiness test and does not cover all items required for the vehicle to be legal - if it did, the cost would be prohibitive. Passing an MOT is unfortunately not definitive proof that the vehicle is fully legal. A vehicle will often get through an MOT with beam deflectors, which is not correct. A vehicle which is to be registered in the UK and which was manufactured (anywhere in the world) since 1986 must be fitted with "the required dipped beam for left-hand traffic". That means that the headlamp must have been type approved to European regulations with the correct beam for left hand traffic. There will be an "e-mark" on the lens, a letter e or E in a small circle with a number, some other numbers nearby and some letters - e.g. HC means Halogen dipped beam, HCR means Halogen dipped and main beam inside one housing. PL means Plastic Lens. As you state, as part of the approval mark headlamp lenses often have a sideways pointing arrow (or arrows) which indicates the traffic side suitability. A few headlamps carry two arrows, pointing to the left and right, these are capable of producing the correct asymmetric beam for both left and right hand traffic with a special adjustment to change between the two, which would normally be performed by the manufacturer on the production line. In the absence of arrows, the headlamps can be shone onto a garage door at night to check the traffic side suitability. This is normally quite clear from the asymmetric wedge of light above the horizontal which lights up the verge. Under the Road Vehicle Lighting Regulations, the vehicle must have the correct type approved headlamp and so modifications performed by anyone other than the headlamp manufacturer are not acceptable. A symmetrical beam is not legal on UK registered vehicles (unless it is fitted to a moped/motorcycle). If a foreign registered vehicle temporarily visits the UK (and vice versa) then some temporary modifications should be made to ensure that the headlamp beam does not dazzle other drivers. Typically sticky tape (or beam converters) is used, although some vehicles have a lever hidden under a cap, under the bonnet, to adapt the beam. I note your comments about how this is enforced in Europe but not over here. Currently the UK Police have no meaningful enforcement powers against foreign motorists, but that will change soon as they will have the powers to levy fines at the roadside, so they might devote more attention to this issue. Finally, it would be possible to have a spare set of right hand traffic headlamps, suitable for Continental Europe, and I feel that it would be legal to change these over on the ferry while heading abroad, as long as they were changed back before the vehicle returned to the UK. You are not committing an offence as the vehicle is not being used on UK roads in this condition. However I do accept that in most circumstances this changeover is impractical. (This advice is the opinion of the DfT, and does not represent the definitive legal position - which can only be provided by a Court of law.)" To summarise the above advice - for any post-1986 UK-registered motorhome (RHD or LHD) to comply with our lighting regulations, it must have unmodified headlamps (i.e. without masks or beam-deflectors) that produce an asymmetric dipped-beam pattern suitable for left-hand traffic usage. Mr Lowe also provided the following relevant links: Base Regulation (Road Vehicles Lighting Regulations 1989: SI 1989 No. 1796 http://www.legislation.hmso.gov.uk/si/si1989/Uksi_19891796_en_1.htm Amendments: http://www.legislation.hmso.gov.uk/si/si1994/Uksi_19942280_en_1.htm http://www.legislation.hmso.gov.uk/si/si1996/Uksi_19963016_en_1.htm http://www.legislation.hmso.gov.uk/si/si2001/20010560.htm EU Directives: http://europa.eu.int/eur-lex/en/search/search_lif.html UN-ECE Regulations: http://www.unece.org/trans/main/wp29/wp29regs.html

[Guest Neal]

Thanks Derek The interesting point for me is that symetrical beams are not legal in the UK (except for motorcycles). Regards Neal

[Guest Will Redfearn Wirral Motorhome Club]

This should be compulsive reading for dealers selling new vehicles on LHD chassis. You know the ones, they maintain that the price difference is to bring the vehicle up to UK spec. Change the sockets to 13amp, and leave the speedo and lights. Three years down the line, it fails its' first MOT on speedo and lights.

[Guest Mel E]

There is a critical additional point here. If you were to have an accident. after dark, in the UK and the Insurance Company's Loss Assessor noticed that your headlamps did not meet the RTLR 1989, you might find difficulty squeezing money from the Insurers. It's a low likelihood but a huge cost if it goes wrong.

[Guest tony downes]

I was very interested in this subject as I have a 1996 RHD fiat ducato which had its mot today, and guess what the tester commented that he thought the headlights were probably lhd ones! The reason for this he showed me was that the left hand one had no pattern and the right showed a right hand assemetrical slant and shoud have a left. He was kind and let me through with a advisory and not a fail. I have had the vehicle for a year and have always thought the lights were very poor and even researched replacing them with a Bosch equivilant as the fiat ones were so bad. Now I can see why. The tester showed me the pattern on his unit to demonstate the problem. What concerns me is that these are good condition original equipment that fiat fitted from new and were considered legal.

[Guest tony downes]

further to my posting above I have bought replacement headlights from Bosch for this vehicle and am looking forward to a night drive to try them out.