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First Drl Related M.o.t Failure?


artscot79
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My mates car failed its m.o.t on the drls fitted reasons where drls were not ce marked therefore ilegal they did not switch

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Nothing to be worried about. If you use chinese lights without CE mark and RL approval you will fail in every country. Lights must be road legal. Other thing is they should be wired properly. I'm not surprised your friend's car failed in such situation.

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My mates car failed its m.o.t on the drls fitted reasons where drls were not ce marked therefore ilegal they did not switch

Artscot what type of DRL did your m8 have fitted , and you say they were not switched , do you mean they were on all the time full with side lights?

Some people are keeping them on all the time and also not following the regulations of where they can be placed on the car , trouble with some after market DRL's are that they don't give out a directional beam they just send out a wide angled bright light.

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  • 6 months later...

Aye, your lights must be CE marked. They don't need to switch automatically, but you do need to be able to at least switch them manually from inside the cabin.

Apart from that, there's no reason to fail for retro-fitted DRLs.

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they werent within the prescribed measurements on the front of the car and they did not go to a low setting with headlights switched on other mot stations i reckon would have put it through but this guy was having none of it in his words what you do after the cars passed is up to you as for what drls im not sure they were eBay and they were marked ones the issue was more of placement

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they werent within the prescribed measurements on the front of the car and they did not go to a low setting with headlights switched on other mot stations i reckon would have put it through but this guy was having none of it in his words what you do after the cars passed is up to you as for what drls im not sure they were ebay and they were marked ones the issue was more of placement

As far as I can tell from the information I've gathered from a bit of googling, there are no regulations, laws or VOSA requirements with regards to retro-fitted DRLs in the UK. I've contacted VOSA for some clarification on this, but other people appear to already have done so and all have received a response that it shouldn't affect the cars ability to pass an MOT.

If it's a car designed after February 2011, then yes, DRLs are subject to inspection, but not before that. The placement issues only apply to manufacturers who want EC certifications for their vehicles and not for retrofitters who put them on a car that already received an EC certification at the time of design.

I'll let you know what VOSA say when they get back to me, but based on the info I already have, I would most definitely be appealing this decision.

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actually i think vosa are wrong drls are supposed to fit within certain measurements ie 400mm in from the edge of the bumper and a certain height to stop dazzling others they should also switch off with full headlights or dim i cant quite remember also read this from a solicitor who prosecuted another driver stating his drls caused the accident Rule 94 of the Highway code states "You MUST NOT use any lights in a way which would dazzle or cause discomfort to other road users". When DRL equipped cars bounce over speed humps headlamps exceed the statutory 1% dip angle and cause dazzle as tested in laboratory conditions.

[Laws RVLR regs 3, 24, & 25, (In Scotland - RTRA 1984 sect 82 (as amended by NRSWA, para 59 of sched 8))]

114 You MUST NOT

  • use any lights in a way which would dazzle or cause discomfort to other road users, including pedestrians, cyclists and horse riders
  • use front or rear fog lights unless visibility is seriously reduced. You MUST switch them off when visibility improves to avoid dazzling other road users (see Rule 226)

Such UK-based groups as Lightmare, the national cyclists’ association CTC, and the Driving Instructors Association have all gone on record as opposing the DRL law.

  • Make sure the lights comply with safety standards - the Ring Daytime Running Lights sold at Halfords are marked ECE R87 so you can be sure they're street legal
  • Only use your DRLs during the day - they will dazzle other drivers at night
  • Most DRLs automatically switch off when headlights are turned on. If yours don't, make sure you manually switch them off when it gets dark.

6.19.4. Position

6.19.4.1. In width: the distance between the inner edges of the apparent surfaces in the direction of the reference axes shall not be less than 600 mm.

This distance may be reduced to 400 mm where the overall width of the vehicle is less than 1,300 mm.

6.19.4.2. In height: above the ground not less than 250 mm nor more than 1,500 mm.

6.19.4.3. In length: at the front of the vehicle. This requirement shall be deemed to be satisfied if the light emitted does not cause discomfort to the driver either directly, or indirectly through the devices for indirect vision and/or other reflecting surfaces of the vehicle.

6.19.5. Geometric visibility

Horizontal: outwards 20° and inwards 20°.

Vertical: upwards 10° and downwards 10°.

6.19.6. Orientation

Towards the front.

thats for new cars the above measurement the problem now is that as older cars are not using these measurements then solicitors are now argiung that the drls in fact dazzled and caused the accident and are being successfull so its up to the individual if the mot inspector believes they may dazzle others then he can fail them

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actually i think vosa are wrong drls are supposed to fit within certain measurements ie 400mm in from the edge of the bumper and a certain height to stop dazzling others they should also switch off with full headlights or dim i cant quite remember also read this from a solicitor who prosecuted another driver stating his drls caused the accident Rule 94 of the Highway code states "You MUST NOT use any lights in a way which would dazzle or cause discomfort to other road users". When DRL equipped cars bounce over speed humps headlamps exceed the statutory 1% dip angle and cause dazzle as tested in laboratory conditions.

[Laws RVLR regs 3, 24, & 25, (In Scotland - RTRA 1984 sect 82 (as amended by NRSWA, para 59 of sched 8))]

114 You MUST NOT

  • use any lights in a way which would dazzle or cause discomfort to other road users, including pedestrians, cyclists and horse riders
  • use front or rear fog lights unless visibility is seriously reduced. You MUST switch them off when visibility improves to avoid dazzling other road users (see Rule 226)

Such UK-based groups as Lightmare, the national cyclists’ association CTC, and the Driving Instructors Association have all gone on record as opposing the DRL law.

  • Make sure the lights comply with safety standards - the Ring Daytime Running Lights sold at Halfords are marked ECE R87 so you can be sure they're street legal
  • Only use your DRLs during the day - they will dazzle other drivers at night
  • Most DRLs automatically switch off when headlights are turned on. If yours don't, make sure you manually switch them off when it gets dark.

6.19.4. Position

6.19.4.1. In width: the distance between the inner edges of the apparent surfaces in the direction of the reference axes shall not be less than 600 mm.

This distance may be reduced to 400 mm where the overall width of the vehicle is less than 1,300 mm.

6.19.4.2. In height: above the ground not less than 250 mm nor more than 1,500 mm.

6.19.4.3. In length: at the front of the vehicle. This requirement shall be deemed to be satisfied if the light emitted does not cause discomfort to the driver either directly, or indirectly through the devices for indirect vision and/or other reflecting surfaces of the vehicle.

6.19.5. Geometric visibility

Horizontal: outwards 20° and inwards 20°.

Vertical: upwards 10° and downwards 10°.

6.19.6. Orientation

Towards the front.

thats for new cars the above measurement the problem now is that as older cars are not using these measurements then solicitors are now argiung that the drls in fact dazzled and caused the accident and are being successfull so its up to the individual if the mot inspector believes they may dazzle others then he can fail them

Just received a response from VOSA. I quote:

"VOSA are the governing body responsible for overseeing the MOT test in the UK. Due to this we would only be able to advise on the MOT requirements for vehicles. However, please note that just because a vehicle passes the MOT it doesn't necessarily mean that it is road legal.

With regards to the MOT I can confirm that running lights are not part of the MOT. Provided they don't effect the operation of another lamp it won't cause the vehicle to fail."

So, straight from the horses mouth - it basically says a person administering an MOT test should not concern themselves whatsoever with DRLs whatsoever (EVEN on new vehicles which are required to have them factory fitted... for certification purposes, but not for VOSA purposes) unless they affect the operation of any other lights.

Okay, they couldn't clarify on road legality or the regulations governing retrofitting (I've sent another mail to the DfT generally for confirmation on that side of things), but that's not the concern of VOSA or any MOT station. They shouldn't be failing you on things that they consider to be non-road legal. They should be checking whether a car meets the VOSA MOT requirements... no more, no less. So if something illegal is on the car, but it isn't an testable item, it should still pass an MOT.

That said, I'm still not convinced that retro-fitted DRLs out of position would constitute and illegal mod, although I'll stand by for the DfT response on that point.

With regards to what you've posted... I agree that any vehicle which has fittings which dazzle other drivers would be illegal, but I don't agree that the positioning of DRLs (unless it's extreme) would cause such a dazzle. Okay, if you're putting them at windscreen level or something, then yes, but not, for example, in the slits of the centre grill of the Focus mk2.

In any case, even legally fitted DRLs will dazzle other drivers in some situations, because the dazzling ability of a light is not only dependent on its position, orientation, brightness, etc. but also on relative road positions. i.e. fully UNECE compliant DRLs could still dazzle and cause an accident if the DRL car is coming over the brow of a hill on a dark country road, or, as you said, going over speed bumps, etc.

In any case, if somebody wanted to sue you, they'd have to provide evidence that your set-up contravenes the RTRA, but they wouldn't be able to use UNECE requirements against you because retrofitted DRLs are not regulated by those requirements.

Will keep you updated with the DfT response when it comes. Could take up to 20 working days apparently, though =\

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its an issue i agree as to where any1 stands i wouldnt mind fitting them but it seems no one is sure as for the mate he did contact vosa who spoke to the tester and upheld the testers decision stating the tester believes the exterior lights fitted constitute a safety issue as these lights did not switch off with headlights activated as they should we believe the testers judgement to be final and within his parameters

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Meh... mine do turn off with headlights and I probably will fit them within the positioning requirements any because I reckon it looks a lot better. Will keep all my e-mails and keep the regulations handy for MOTers and police, etc :).

Did your mate have a manual on-off switch in the cabin, or were the lights just constantly one with the ignition with no option to turn them off either manually or auto?

If he had the switch, I can't see how they could possible fail him... because then it'd be the exact same situation as forward fogs.

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no switch they were eBay jobs that were permanantly on he has changed them to the ones that wire to the sidelights and switch off when headlights are switched on they also dim now with sidelights on

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