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2012 new MOT rules


T A Terminator
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8th gen 2.4 Manual
Guys just found this today and is very informative.This IMO is the truth about MOT rules.
Rules on HID'S is section 1.7

Great stuff Brett, so it seems pretty clear that there is no issue with retro-fitted HID kits ;)

It's very clear that cars with HID light 'may' also have self levelling and washers.
Guys after reading through some of this link iv just seen this is edition 4 2011 :rolleyes:
So this might change again in 2012.
No i was right on the 1st page it says issue date 1st Jan 2012 ;)
Brett is this an extension of the debate which was had previously on this thread?

The document you've linked to is the inspection manual which, as identified by Faddy in this thread and by me in the link above link, states 'MAY'.

But in the testing directive which Saj clarifies the difference between in the above thread it states:

The presence and operation of these headlamp cleaning and levelling devices has been added to the test. Therefore, if a mandatory headlamp levelling or cleaning device is missing, inoperative or otherwise obviously defective, the vehicle will fail.
This raises the question of whether these checks apply to vehicles fitted with after-market HID lighting kits. These kits convert conventional halogen headlamps to HID Xenon and they are widely sold and fitted to vehicles used on the road. The Department for Transport considers that after-market systems should be required to meet the same safety standards as that applied in respect of these lamps at vehicle Type Approval. Therefore, in order to pass the MOT test, vehicles fitted with after-market HID systems would also need to be fitted with headlamp cleaning and self-levelling systems.

The testing directive says the devices have to be fitted and working, and the inspection manual states how to test if they are fitted. The testing directive (which determines the pass/fail elements of the MOT) is what will be followed.
Doc I'm only quoting a link here.As for the impact on these new MOT rules I think we need to wait and see.
I was reading a foram today and 1guy stated if your car needs all electric devices working like electric seats this will cost a fortune.
No MOT is ever going to need all electric devices working. That would mean you failed your test because the stereo doesn't work.
The MOT is to prove your vehicle is roadworthy at the time of the test.
Doc I'm only quoting a link here.As for the impact on these new MOT rules I think we need to wait and see.
I was reading a foram today and 1guy stated if your car needs all electric devices working like electric seats this will cost a fortune.
As someone said in the previous thread, I think it would be a very fussy mechanic who failed a car on an after market HID conversion because it didn't have the auto levellers and washers. But best buy your mechanic a xmas pressie and start sweetening him up, just in case. I'm sure we will start to get feed back from members in the new year after they have their MOT's so we can start to gauge it's impact. No doubt there will be the odd one or two who fall foul of this rule though. But personally I can't see it being a real problem. (famous last words before I have to rip my HID's out! :D )

Sounds like the guy on the other forum hasn't quite got to grips with the purpose of an MOT. Having a cold *** because you have electric seats don't work will never make a car un-roadworthy. :lol:
Good shout Doc I might change mine after the new rules are in.
This way I can see the feed back of the mot testers lol
Just leave the HIDs in, give the mot place something to fail it on, rather than been picky on something else, then just unplug them, stick em back in, no big deal.

Or just quote this: "Headlamps are not required to be fitted to vehicles used only during the hours of daylight, which are fitted with neither front nor rear position lamps, etc"

Go there with no headlights at all lol. be sure to make it home before dark tho!
And section 3.4 now has the combined anti-lock brake plus electronic stability control failure.

Or, in other words, £1000+ repairs for 7th gen diesels with a knackered Bosch VSA modulator. Tempting fate but mines still fine. Perhaps depends if examiner knows the car has an stability control if not flagged on MOT computer and the bulbs are removed...
I went down to see my mechanic today to discuss the new 2012 MOT rule changes regarding HID headlights and aftermarket conversions. I went in expecting him to have already received the new paperwork only to be told they don't receive it until a week into the new year. :huh: He then mentioned that VOSA send out a DVD (approx 22:30 long) full of ham acting giving mechanics a step by step guide on the new MOT changes and how to test for them. This was duly lent to me and watched. The new regulations are number 2010/48/EU.

It has been discussed before that there are 2 documents, the testing directive and the inspection manual. Simply, the inspection manual (the guide the mechanic uses to MOT the car) is VOSA's physical testing interpretation of the testing directive. I.e. what the tester is physically required to do to complete the MOT test. As such from a mechanics point of view the inspection manual is the final word on an MOT pass or fail.

In regard to the new headlight regulations "headlight washers must be present and working when tested on any HID or LED headlight which produces over 2000 lumens". Also "most of these systems generally require a self levelling device". Some self levellers will (when the headlights are first illuminated) move up and down to set themselves in the correct position, others will not. The only way to test the systems which don't move upon initial illumination, to see if they are working, would be to jack up the front or back of the car, disturbing the balance of the car, cause the activation of the self levellers. As this is not practical, and therefore not testable, it has been decreed that "if the tester is not sure if the system is not working the benefit of the doubt should be given to the presenter of the vehicle". My mechanic has said that unless it is pointed out to him that my car has manually adjusted headlight levelling he will, as I have HID’s, ***ume them to be automatic and working. B) Other more uncooperative mechanics however may notice the manual headlight adjustment switch and choose to fail the car.

There are also some other changes which have now become part of the MOT which are worth noting:

Electronic stability control (VSA) visual inspection. If the MIL is illuminated then the car will fail the MOT. When the ignition is initially turned on the MIL light has to be “present, working and not indicating a fault”. So pulling the bulb out the dash because you have a faulty VSA will get you round an MOT. Also if the device has a switch to turn it off it must “not be insecure or faulty” otherwise that will also cause a MOT fail. “A vehicle should only be rejected if it is clear it is indicating a system malfunction”. Basically, because a road test is not part of the MOT the device can’t be tested practically. So if the MIL turns off after the ignition is initially turned on the device is deemed to be working.

Indirect vision devices AKA rear view cameras. These are now tested the same way as mirrors. So if these are “missing, obscured or the vision is seriously impaired” then they will fail an MOT. So if you have fitted an aftermarket rear view camera make sure it is working, or take it out, or risk an MOT fail.

Please note: The quotes in the above paragraphs have been taken directly from the VOSA regulations 2010/48/EU DVD.
Well ill see tomorrow as its mot day then
I'm pretty sure different MOT places will tell you different things, at least for a while - if it fails, take it somewhere else! :D

Anyone noticed the Testing Directive which states the confusing suggestions about self-leveling being required on all retrofits, is actually within the "Commercial Vehicle Testing Manuals" section of the VOSA site:
(Technical Pen Picture 3 - Lighting)
It's the Proposed MOT Inspection Manual - Class IV, V and VII (January 2012) which says test if fitted.
I read today that any failures under the new rules will classed as advisories for the first three months. From the 1st April they will be failures.
I think people with HID's in normal reflector housings have ALOT more to worry about than us with our projectors & washers ;).

i honestly dont see why they would fail us... as long as the AIM of the beam is correct and they get washed, the MOT'r wont be that fussed about leveling system.
Mine's not till October so hopefully we'll know by then! :D
This looks like a good list:

One point someone was asking about ABS being removed:
"ABS system component obviously missing"

As for HID, it does clearly say:
"Headlamp levelling or cleaning device inoperative or obviously defective (LED or HID headlamps only)."
Which still sounds like it's only tested if fitted to me.
Well I got a mot failure on handbrake efficiency, doh! Turns out its not a bad thing really, as they never mentioned my HiD's, nor my Jap size number plates so thats all good. The best thing is i got an EP3 courtesy car from funkypower for a week so i'll get my car back next week with a fresh mot, and they'll have time to mock up my diffuser too B)
I've just had a reply from VOSA Operations Directorate, I'd asked 3 questions:

Trev said:
1) The biggest question seems to be over after market HID kits, do they require washers and auto-levelling to be fitted?
The first evidence that people come up with is the PEN:
Which suggests “after-market systems should be required to meet the same safety standards as that applied in respect of these lamps at vehicle Type Approval. Therefore, in order to pass the MOT test, vehicles fitted with after-market HID systems would also need to be fitted with headlamp cleaning and self-levelling systems”, but then the MOT Inspection Manual:
http://www.dft.gov.uk/vosa/repository/MOT Inspection Manual.pdf
Says that “...headlamps may be fitted with headlamp washers and a suspension or headlamp self levelling system. Where such systems are fitted, they must work”, so the vehicle will only fail an MOT if the systems are there but don’t work, rather than if they’re not installed at all.
VOSA said:
1) For legal advice on the fitment of HID kits I would advise to contact DfT and I've attached a link to a statement on their web site
From an MOT perspective the Inspection Manual (IM) applies to passenger vehicles and if presented for test with HID headlamps it will be tested accordingly.
However the IM does advise that it is not always possible to readily determine whether HID lamps are fitted and if there is doubt "benefit of doubt" should be given.
That DfT page is pretty old, suggesting the law hasn't actually changed from what it always was, legally you're in trouble for using aftermarket HID kits but has anyone ever been stopped by Police and told to remove them?
The MOT test is as it is in the inspection manual, so no real change to previous in that it only has to work if it's fitted. The problem is the perception of it among MOT testers has changed as shown by various people who have spoken to garages, which means you need to find one who's actually RTFM, or is nice and friendly.

Trev said:
2) Alterations to ECU maps or ECUs will fail?
I can’t find anything on official test documentation to suggest that ECUs will be tested in any way, yet people are claiming vehicles will fail if the ECU has been tampered with. Obviously there are a lot of modified cars on the roads with remapped ECUs, and some highly modified vehicles have new replacement ECUs.
The only relevant thing I can see is from the MOT Inspection Manual, which states “Repairs and modifications to vehicles must be ***essed on their merits, taking account of the nature and function of the component. The main criterion to be used when ***essing repairs is whether the repair is obviously likely to adversely affect the roadworthiness of the vehicle. In respect of modifications, the main criterion should be whether the modification has seriously weakened the component.”. This obviously suggests that 99% of ECU remaps and replacements will pass an MOT? There does seem to be a new rule about unsafe wiring, which I guess could be linked to ECU retrofits, is this maybe where the confusion is coming from?
VOSA said:
2) ECUs will not be testable. The component criterion refered to only applies to those testable components which are specifically stated in the Inspection Manual. As ECUs are not stated there will not be a relevant reason for rejection (RfR). Section 1.9 does refer to an inspection of visible wiring but has very specific RfRs for damage or the likelihood of damage and exposed conductors. Modification to wiring would not be a failure unless it met the specific RfRs. Given the location of modern ECUs it is probable that the wiring will not be visible anyway.
So no problems with ECUs or remaps.

Trev said:
3) Modified suspension and/or wheels will fail?
This seems to be the same argument as above, again there are a lot of vehicles which would be put off the roads if they were to fail suspension and wheels that are different to OEM spec.
VOSA said:
3) There are no new RfRs for modified suspension or wheels that differ from OEM.
However there is a new Method of Inspection (IM 2.4 A2) which refers to a suspension component for inappropriate repair or modification and has a corresponding RfR where the repair or modification has seriously weakened the component.
Again, no problems as long as the fitting is safe - so don't go hacking off the top of your spring to lower your car basically.
Trev your a star :)

Nice bit of info from the horses mouth!

I guess people are getting so caught up on what 'may' happen, they are forgetting that the MOT testers are human and cant check everything to do with each car they MOT.

MOT's would dake a full day if they did!
Thinking aswell of instances where the Engine Management Light stays on, or comes on intermittently when driving along and the dealer/scan tool can't find a fault. How would someone get around that, as obviously removing the bulb results in a fail now? I've also heard that the steering lock needs to be working too. Mine isn't :rolleyes: is the steering lock really safety related? I thought it was just a there to give thieves a hard time?
Now, our 7th gens on the whole are OK, they're designed to have 'em less some frilly controls; so the effect is not too bad, but when you get numpties whizzing around with illegal HIDs - its really starting to bug me. Especially as by design these Corsa drivers are more likely to tailgate you. And I am not one to hang around either.

My current practice is to slow down to an annoying yet consistently safe pace with other traffic, and stick my rear fogs on.

Now, fogs.... why do people insist on putting their front fogs on before some small insect in central Europe has decided to take a whizz. HEAVY FOG ONLY PEOPLE! A light drizzle doesn't count.

Sorry.... rant over.
I've had further clarification from VOSA on HIDs:

Ref: changes coming in April/May:
VOSA said:
The inspection manual as currently published gives the full RfRs. There is the possibility of minor modifications (eg an acceptance of specialist modifications for certain vehicles regarding steering wheel airbags is being considered), but testers should include all the items in the Inspection Manual in their examination of the vehicles at this time.
So they're not changing the RfRs as they are in the current Inspection Manual, which says things like '...may be fitted...'.

He sent me this link:
Page 6, Annex B:List of New Testable Components:
Headlamp levelling and cleaning devices when fitted for HID or LED headlamps

And finally:
VOSA said:
may I clarify something regarding HID lights. HID lamps that have an output of less than 2000 Lumens do not need headlamp levelling or washing. LED lamps under 2000 Lumens must have self levelling, but do not need washing.

It is also not possible for an MOT tester to determine whether or not a particular lamp is more than 2000 Lumens or not. The MOT test therefore uses the lowest criteria that can realistically be applied; so if a particular vehicle is fitted with a headlamp levelling or washing system, then we consider it logical to ***ume that it requires it by law and therefore it must work.

Having said all that, we'll probably need to print all these documents off and take them with us when we get MOTs done. :D
There are a lot of low riding VW owners worried about this just now. Especially the mad ones who decided that chassis notching was a good idea to get as low as they could.
MOT tomorrow. Lets see on the HID's! Mine has washers and projectors. Just no auto-levelling. Let's see if they notice.
MOT tomorrow. Lets see on the HID's! Mine has washers and projectors. Just no auto-levelling. Let's see if they notice.
Ok,let me know.I am worry,because i don't have self leveling and no washers.
Ok,let me know.I am worry,because i don't have self leveling and no washers.
Tomas i think the washers will be the give away IMO.This is why im holding off for the min on my car for this reason.
April is the time when all this kicks in so will be interesting to see what happens.
Adam are headlight washers only on EX spec but must admit iv nether heard a 7th gen without them.
you dont have self leveling but you must have washers. i dont know of any 7th gen without headlight washers.
But my car doesn't have washers