HID Lights in the NCT

listermint

Wibbs wrote: »

*heads desk* Jesus, LM how much evidence/convincing do you require?

I know my model of car backwards, I know the options, I'm even sad enough to have a pretty good overview of the different models/options across different markets(red back seats in the Canadian one the oddest) and I can happily state with no fear of contradiction that Japanese domestic market 98 spec type R's never came without HID's and never had washers(or levelers). Indeed if you can find me an original 98 spec R as it left the factory minus HID's I'll give the keys to my car.

Since HID/Xenon lighting was introduced many models of cars from many different manufacturers had no option for washers and others had no option for leveling, manual or automatic. This is a fact, no if's buts, maybes.

I posted that response before you actually provided the detail yoo obviously hit post at the same time. So thanks for the detail, giving people answers rather than being obtuse is better dont you think.

Chimaera

Regarding what the NCT manual says, it's a guidance document provided for the test centres and the general public so people don't have to dig through the regulations. If there's a query, the relevant SI or ECE regulation takes precedence.

I'm trying to dig through the info on ECE regs but it's time consuming and I'm busy at work. The relevant regulations for HIDs are ECE R48 which governs general lighting requirements for vehicles, and ECE R98 which specifically deals with HID lighting systems. According to a Hella guidance document I came across R48 prohibits retrofits which don't include washers and automatic levellers (http://www.webcitation.org/5qIMaJAZS).

Wibbs

listermint wrote: »

I posted that response before you actually provided the detail yoo obviously hit post at the same time. So thanks for the detail, giving people answers rather than being obtuse is better dont you think.

People have been stating quite clearly for the last three pages that there were many models of cars(and examples given) where they were type approved and didn't come with washers. In the case of Djimis car the manufacturer stated that they didn't from factory. Since then you seem to find this somehow confusing as surely all cars type approved must have these devices, hence my frustration.

Chimaera wrote: »

Regarding what the NCT manual says, it's a guidance document provided for the test centres and the general public so people don't have to dig through the regulations. If there's a query, the relevant SI or ECE regulation takes precedence.

I'm trying to dig through the info on ECE regs but it's time consuming and I'm busy at work. The relevant regulations for HIDs are ECE R48 which governs general lighting requirements for vehicles, and ECE R98 which specifically deals with HID lighting systems. According to a Hella guidance document I came across R48 prohibits retrofits which don't include washers and automatic levellers (http://www.webcitation.org/5qIMaJAZS).

Earlier slimjimmc posted the relevant section from the government statutes, so this may save some digging. He did the work for us *tips hat*

(1) By adding the following reasons for refusal to Item 30 of the Schedule—

(15) light source and lamp not compatible.

(16) where a levelling device is mandatory, the levelling device is not operating.

(17) where a levelling device is mandatory, the levelling device cannot be operated from the driver’s seat.

(18) where a headlamp cleaning device is mandatory, the headlamp cleaning device is not operating correctly.

The keyword seems to be "mandatory", where regulations insisted manufacturers installed such devices after a certain date to get type approval. In the case of the numerous examples of older pre regulation cars this wouldn't apply. By the nature of it it can't be retroactive, otherwise as I noted other newer regulations calling for mandatory catalytic converters and the like would have to be retrofitted to older cars.

thats not gone well

Wibbs wrote: »

People have been stating quite clearly for the last three pages that there were many models of cars(and examples given) where they were type approved and didn't come with washers. In the case of Djimis car the manufacturer stated that they didn't from factory. Since then you seem to find this somehow confusing as surely all cars type approved must have these devices, hence my frustration.

The keyword seems to be "mandatory", where regulations insisted manufacturers installed such devices after a certain date to get type approval. In the case of the numerous examples of older pre regulation cars this wouldn't apply. By the nature of it it can't be retroactive, otherwise as I noted other newer regulations calling for mandatory catalytic converters and the like would have to be retrofitted to older cars.

What I can't quite grasp is how an 02/03 merc has HIDs no levelling/washing yet the factory volvo one of the same year does.

How can both cars be type approved and conform to specs if both light setups are so different?

Wibbs

I'd reckon the simplest answer T is that this was pre the regs being set in stone and some manufacturers offered the devices while others didn't. Now they all have to, in the EU anyway. I wouldn't be surprised to find that in other markets they don't have them, or they're options. Cheaper to build and all that.

Airbags would be a similar kinda thing. Before they were mandatory some makers had them in some models, or they were an option. Actually the Integra is another example of this. In Japan it was an option delete(mine doesn't have them, indeed the only option it came with was air con), but for the same years in the UK and Europe they were non optional and fitted as standard(same story with ABS too).

Chimaera

You also have the situation where a model is being redesigned and the new one is designed to have those features added knowing that the regulation will be coming into force within the lifetime of the vehicle. It's similar to how a bunch of '10 and '11 cars have DRLs even though they weren't yet compulsory at that time. The regulation was imminent and it was easier to introduce them at that point.

The keyword seems to be "mandatory", where regulations insisted manufacturers installed such devices after a certain date to get type approval. In the case of the numerous examples of older pre regulation cars this wouldn't apply. By the nature of it it can't be retroactive, otherwise as I noted other newer regulations calling for mandatory catalytic converters and the like would have to be retrofitted to older cars.

It's still referring back to the relevant ECE regulations though. So the SI basically says if the ECE regulation in force at the time your vehicle was built demands washers and levellers you better have them, otherwise you're ok.

Wibbs

Chimaera wrote: »

It's still referring back to the relevant ECE regulations though. So the SI basically says if the ECE regulation in force at the time your vehicle was built demands washers and levellers you better have them, otherwise you're ok.

The problem seems to be C, that the NCT manual doesn't take this into account and says ALL cars with HID's have to have these devices, regardless of age. Hence some testers are failing cars like Djimi's.

Chimaera

I think that's an implementation/training issue for NCTS and a few well thought-out complaints on the matter will probably smarten them up. Their job is to ensure vehicles meet the relevant standards for safety and emissions related components and those standards are ultimately the ECE regulations.

slimjimmc

Paddy@CIRL wrote: »

Does anyone know when the EU regulation was introduced that made the washers / levellers mandatory?

djimi wrote: »

HID was the only headlight option in the 98 spec Type R Integra. It came with neither an adjuster or a washer. I have confirmed this with Honda.

Chimaera wrote: »

You also have the situation where a model is being redesigned and the new one is designed to have those features added knowing that the regulation will be coming into force within the lifetime of the vehicle. It's similar to how a bunch of '10 and '11 cars have DRLs even though they weren't yet compulsory at that time. The regulation was imminent and it was easier to introduce them at that point.



It's still referring back to the relevant ECE regulations though. So the SI basically says if the ECE regulation in force at the time your vehicle was built demands washers and levellers you better have them, otherwise you're ok.

The earliest reference to HIDs in Irish type-approval law is in SI 147/2000. The SI also refers to EC Directive 97/836/EC (Nov 1997) in which the EC accept the UN/ECE regs for motor vehicles.

So, from what I can find it appears that HIDs have been regulated since end 1997 for all type-approval of future new vehicle releases/designs. Anyone driving a car with pre-97/836/EC type approval is free from its requirements even if wasn't built until much later.

I haven't dug deep enough to see if washers and levelling was included in the 97 regs or came later.

Wibbs

Some good digging for info there SJ

slimjimmc wrote: »

I haven't dug deep enough to see if washers and levelling was included in the 97 regs or came later.

I'd think later SJ, given I know a few later (2003) Irish bought European spec(and manufactured( cars that didn't have the washers(Merc/BM/Porsche).

Wibbs

By the by, I found the relevant page originally handily posted by dougie-lampkin in another recent HID/NCT thread on the subject;



It mentions mandatory, but doesn't qualify it by saying "where a headlamp cleaning device is mandatory" like in the government regs SJ posted earlier. It simply says "mandatory" so it could be read like this is applicable to all such lighting systems regardless of year of build/type approval(and it reads as if leveling is a given), thus adding to possible confusion on the matter like in Djimi's case. To muddy the waters further the EU regs apparently say that cars with "sports suspension" don't have to have self leveling. The UK MOT allows for this apparently, though god knows what is meant. I'll try and dig up more info there.

ondafly

just to add to this;

I have a 2002 Impreza with factory HIDs, no headlight washer, but does have a manual leveller. I believe the next model Impreza 2003 to 2005 also with factory HIDs doesn't have a headlight washer. I have my NCT on the 8th of March, and I've had the car through 3 NCTs with no issues previously will be interesting to see what happens.

My M3 also had factory fit HIDs with a leveller attached to the suspension. You wouldn't believe the amount of these levellers I've seen snapped and not working.

slimjimmc

Ok, found this 111 page pdf of UN/ECE Regulation 48 on RSA's website. http://www.rsa.ie/Documents/Vehicle%20Testing/veh_test_pubs/Regulation%2048%20UNECE.pdf

I read it as saying if your car can keep the HID dipped beam within the limits when parked with various loads on board (Annex 5) then manual adjusters are ok, otherwise it needs auto adjusters. This probably explain why cars which have self-levelling or, as Wibbs mentioned in post #72, cars with sports suspensions don't need auto-adjusters.

6.2.6.1.2. Depending on the mounting height in metres (h) of the lower edge of the apparent
surface in the direction of the reference axis of the dipped-beam headlamp,
measured on the unladen vehicles, the vertical inclination of the cut-off of the
dipped- beam shall, under all the static conditions of Annex 5, remain between the
following limits and the initial aiming shall have the following values:

6.2.6.2. Headlamp levelling device
6.2.6.2.1. In the case where a headlamp levelling device is necessary to satisfy the
requirements of paragraphs 6.2.6.1.1. and 6.2.6.1.2., the device shall be
automatic.
6.2.6.2.2. However, devices which are adjusted manually, either continuously or
non-continuously, shall be permitted, provided they have a stop position at which
the lamps can be returned to the initial inclination defined in paragraph 6.2.6.1.1.
by means of the usual adjusting screws or similar means.
These manually adjustable devices must be operable from the driver's seat.
Continually adjustable devices must have reference marks indicating the loading
conditions that require adjustment of the dipped-beam.

Cleaning system required but only if your lights are bright enough.

6.2.9
Dipped-beam headlamps with a light source having an objective luminous flux
which exceeds 2,000 lumen shall only be installed in conjunction with the
installation of headlamp cleaning device(s) according to Regulation No. 45. 8/

Note that the levelling and cleaning regs only apply to dipped lamps (passing lamps) not the main beam.

The above are from Rev 5 dated 22nd May 2008. I cannot find earlier issues so I can't say if this is when the above requirements were first introduced.

Current UN/ECE regs can be found at http://www.unece.org/trans/main/wp29/wp29regs41-60.html

Wibbs

Slimjimmc, helpfully adding facts not opinions into the debate. Kudos.

slimjimmc

Thanks Wibbs, only wish I could confirm date the regs were first introduced but I'm afraid it has me beaten. It was an interesting journey none the less.

Doom

Wibbs wrote: »

This very subject lately came up in the Upgrades and Audio forum. The NCT manual clearly states that no HID setup will pass without self leveling and washers. However from the factory my car has neither and HID's and has never failed, nor was any comment made.

I suspect/hope that it only applies to cars after a particular date when EU legislation came in and any cars with HID's fitted as standard from the manufacturers minus these two requirements are OK and will pass. Like I say mine has and a couple of people I know in a similar boat have passed. It seems the NCT guys on the ground have the common sense to understand this.

I hope this is the case anyway as it would be utterly daft to retrospectively fail cars that were built like this outa the box(they'd also have to fail older models without cat converters, ABS etc too, going by this logic). Then again I'd not put it past the bodies responsible, citing "safety" or somesuch nonsense.

PS my car passed in 2013 with HID's minus washers and levelers.

So you've no respect for other road users and like to blind oncoming traffic to 'be cool'

slimjimmc

Doom wrote: »

So you've no respect for other road users and like to blind oncoming traffic to 'be cool'

His car has factory fitted HIDs so they're unlikely to blind oncoming traffic unlike the retro-fit crew who stick HIDs into reflector lenses.

slimjimmc

Doom wrote: »

"The NCT manual clearly states that no HID setup will pass without self leveling and washers. However from the factory my car has neither"
I'm right as per NCTmanual, Wibbs car should not pass.
Mod needs a chill pill.

UN/ECE vehicle type-approval does not make self levelling and washers mandatory for all vehicles. Some vehicles have HIDs but do not require self-levelling or washers and are legally allowed on Irish roads.
Irish legislation says where "mandatory" (see Post 36).

The NCT Manual is a guide not gospel and doesn't cover all situations, it's the legislation that's important.
Anyone who can show their car is exempt from a requirement in the NCT can pass.

djimi

Right. I now have my NCT cert for my car. Im not sure exactly what was done, but after I failed the first time I got in contact with Honda, who confirmed that the lights on my car are standard from factory and that there is no non-HID option that I could install in their place. They made some calls (to NCT and RSA I think), and the bottom line is that a memo was sent to the NCT center to say that my car was okay to pass.

I dont know the specifics of what was said or done, but anyone who was in a similar position to myself, where their car has factory spec stock HID headlights that cannot meet this regulation, would be advised to contact the manufacturer of their car and see what they can do to help, because it seems that there is some scope for exceptions to be made.

Paddy@CIRL

I was speaking to a friend of mine today who had a similar problem with his E39. His car has OEM xenon headlights without washers or automatic levelling and went through the test on Wednesday gone. He left a letter from a local main dealer on the passenger seat stating that the car was fitted with factory equipped xenon lights and came without washers and automatic levelling.

He passed with no issues.

Wibbs

djimi wrote: »

Right. I now have my NCT cert for my car. Im not sure exactly what was done, but after I failed the first time I got in contact with Honda, who confirmed that the lights on my car are standard from factory and that there is no non-HID option that I could install in their place. They made some calls (to NCT and RSA I think), and the bottom line is that a memo was sent to the NCT center to say that my car was okay to pass.

Nice one Djimi and fair play Honda. Still, pain in the arse that you had to go through that hassle for what should be as obvious as the nose on ones face for even the most dimwitted. I wonder did that memo go through all test centres or just yours, or will every owner of such a car in other test centres have to go through the same ill informed bullshít as you did?

This could get truly silly when one considers that many early noughties E class Mercs had no washers and they were very popular and many are still on the road. Never mind al the other marques and models of car in a similar situation. Talk about employing the hard of thinking to write up the "official" manual of the NCT. :rolleyes:

djimi

To be honest, I dont entirely blame the NCT in this; as far as I can gather this has been in their guidebook for a couple of years but they have been overlooking it until they were specifically told not to from the start of this year. The problem seems to be with the RSA(?), and the guidelines that they hand down to the NCT. Its a poorly written regulation and doesnt take into account the numerous cars that simply cannot meet it, but I sort of get the impression that they were prepared to deal with individual models and cases as and when they arose, rather than actually writing the regulation properly in the first place to deal with them.

I have to say fair play to Honda in all this; they were fantastic to deal with and very helpful. There is a reason that I am on my third of most likely many Honda cars

Cee-Jay-Cee

My 2005 Legacy passed NCT (a few weeks ago) with an aftermarket HID kit fitted. I had the headlights alignment checked prior and it was perfect. Passed no problem. They're projector lights which ensures a nice even and clean cut off and so they're not dazzling like when fitted to reflector type headlights.

Wibbs

Wibbs wrote: »

I have my NCT coming up this Sunday, so I wonder will any comment about my non leveling, non washing factory HID's be made? I'll report back anyway, though I doubt anything will be said as the car has passed every NCT since 07.

Well as promised... I was getting the fear because for some reason the guys in front of me were failing left right and centre and even passes were being told to keep an eye on X Y Z. My name called and PASSED. Just like every time before. No mention of HID issues so... Of course it seems from Djimi's experience your milage may vary.

djimi

Which centre did you do the test in? I wonder if its a case that all centres have been notified that HID lights in a DC2 are not to considered a fail (provided its not HID bulbs jammed into standard headlamps).

Wibbs

Greenhills

Wibbs

djimi wrote: »

Which centre did you do the test in? I wonder if its a case that all centres have been notified that HID lights in a DC2 are not to considered a fail (provided its not HID bulbs jammed into standard headlamps).

Hopefully and that goes for all the other car models similarly affected.

djimi

My hope is that as each case is brought for this issue that the model of car is added to an exempt list (one does seem to exist as the first girl that I spoke to in the NCT service centre checked that my car was not on it). Whether or not this is the case, or whether testers will actually refer to this list, is questionable, but at least there does seem to be a sensible resolution available, even if it might mean having to put up a fight.

Im glad to hear that you were able to pass without issue.

dr.fuzzenstein

Wibbs wrote: »

Well as promised... I was getting the fear because for some reason the guys in front of me were failing left right and centre and even passes were being told to keep an eye on X Y Z. My name called and PASSED. Just like every time before. No mention of HID issues so... Of course it seems from Djimi's experience your milage may vary.

It's just how we deal with legislation in this country.
In civilised countries, legislation that is not fit for purpose gets modified until it is fit. There is no if or but or maybe, everyone knows what the score is, what you can and cannot do and there is no room for "ah, be grand"
Here, "ah shure, no-one takes that stuff seriously, ah, you'll be grand, you just have to get the right tester, gard, judge, etc..., t'will do the finesht"
So the authorities know that the legislation was written by morons who don't care and they'll match that with their own lazy attitude.
Of course if you do get the one guy that delights in fcuking people for the sake of it, you're fcuked.
There are lazy and overpaid bureaucrats in other countries too, as well as incompetent law enforcement, but only here you get the feeling that the law and it's enforcement is only a bit of a laugh, ah shure, no one takes that stuff seriously.

Wibbs

Add in the Joe Duffy subset. The gullible, the slow witted, the vested interests, the people full of ill informed opinion, with a correspondingly high level of self confidence to air that in public and confuse it with fact and you're truly boned. This occurs in many areas of Irish life, but given the forum subject we're exposed to more of it than some areas.

I recall listening to the radio around the time of the switch to metric road signage. Some afternoon show on some station or other. Well they had the usual suspects on air. I think one of them actually had some facts and feeling for the subject, the rest were morons and that's an insult to morons. One councilor from some some town or other west of the Shannon was complaining about "de new speed limits in de town", concerned that people would be confused(he'd know) and that the speed limits went up. IIRC some of these signs had read 40 MPH beforehand and now would read 50 KPH. The woman on the panel who had stockpiled the brains for herself helpfully pointed out that this was actually slower. Gombeenman's reply. "but tis fierce fasht for the kilometer". People had actually voted for that level of intelligence.

Unfortunately the rest of us have often to contend with this kinda thing as fallout from above. This a case in point. Some cubicle dweller in a fit of civic duty writes up the NCT handbook, leaving a potential pain in the exhaust likely. The NCT guys ignore this for years. Some other cubicle dweller hoofed up on the goofballs Joe Duffy is pimping decides to take action against "those zenon(sic) lights", leaving the NCT guys to deal with the mess from customers. Especially the testers themselves as they would know all this as they are mechanics.

Ah well, all's well that ends well, for me and Djimi and whichever cars they've added to the list anyway. Others may have to go through similar BS to get their cert.