New Motorcycle Mot Rules For 2021

Discussion in 'Triumph General Discussion' started by David Cooper, Jan 14, 2021.

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  1. Tricky-Dicky

    Tricky-Dicky Crème de la Crème

    Dec 12, 2016
    2,445
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    Norfolk UK
    #41 Tricky-Dicky, Jan 19, 2021
    Last edited: Jan 19, 2021
    Won't have to worry about the Trident...however I have recently fitted the Civic with LEDs as i god fed up with being blinded by oncoming traffic with LED that are apparently not adjusted right as they are far to blinding.

    The main reason they don't want you to fit LEDs/HIDs are because the reflectors are not suited however its mainly to do with alignment/focus and cut of on dip BUT most LEDs bulbs are adjustable, so you can achieve the same beam pattern....not going to change them back before my MOT which is soon so will see if they automatically fail it.
     
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  2. Gyp

    Gyp Well-Known Member

    May 13, 2020
    391
    63
    United Kingdom
    So... what about sidelight bulbs?

    My sidelight bulb is LED, and that it within the halogen headlamp shell. The original sidelight bulb is not halogen.
     
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  3. Gyp

    Gyp Well-Known Member

    May 13, 2020
    391
    63
    United Kingdom
    One thing I have found odd for years is the ability of Triumph motorcycles, not the Classics but the Roadsters and Adventurers to dazzle oncoming traffic, just with standard headlights.

    Even the missus says "here comes a Triumph" when we see just a headlight coming towards us in the far distance.
     
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  4. Windy

    Windy First Class Member

    Aug 16, 2019
    567
    693
    Shropshire
    Got the MOT done today and it passed with a whole LED light unit fitted, took the old one along for the ride just in case:).

    I have a wisamic 5-3\4.5 5.75 inch led off Amazon at around £45, been fitted for 18 months and going strong, just in case anyone is interested.
    upload_2021-1-20_18-27-42.jpeg
     
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  5. joe mc donald

    Subscriber

    Dec 26, 2014
    13,920
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    slough / burnham
    Just another big scam to rid the roads of motorcycles. Here in the UK they have hated bike for to long and I don't see it changing any time soon.
    Joe.
     
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  6. Triumphal385

    Triumphal385 Active Member

    Mar 23, 2020
    134
    43
    South East
    I've sent in an email, asking for clarification and the reason for the requirement. I won't hold my breath for an answer, but if I get one, I'll let you guys know.
     
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  7. Triumphal385

    Triumphal385 Active Member

    Mar 23, 2020
    134
    43
    South East
    Interesting Response. I note they don't refer to any Legislative authority.
    If someone here could double-check my findings, I'd appreciate feedback.

    The relevant legislation, is the Road Vehicles Lighting Regulations 1989.
    Regulation 18, requires compliance with Schedule 4, Part 1 .

    Sc. 4, Pt. 1, requires a solo motor bicycle to be fitted with (at least ) 1 headlamp, subject to exceptions.
    Sc. 4.1.5 refers to the need for "An approval mark or British Standard Mark". For a solo m/c, it makes "No Requirement".
    Sc. 4.1.8 requires a solo m/c exceeding 250cc, to be 24 Watts minimum.

    24 Watts, equates to 90 Lumens.

    I see no requirement, for a "Homologated" (approved) marking on an LED bulb, within RVLR 1989, as Sc. 4.1.5, makes "No Requirement".

    It appears to me, that DVSA are fabricating their own requirements, regardless of what the Law actually states. It's not the first time that I have known them to do this.

    I'll see if I get a reply, then maybe raise it with my MP.

    Any views?
     
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  8. Notso

    Notso Senior Member

    Dec 17, 2018
    626
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    Solihull

    Regulation 18 uses 'shall' in relation to the requirements in column 2, that includes the markings. I think makes it mandatory in law.

    Obligatory lamps, reflectors, rear markings and devices
    18.—(1) Save as provided in the foregoing provisions of these Regulations and in paragraph (2), every vehicle of a class specified in a Table in Schedule 1 shall be fitted with lamps, reflectors, rear markings and devices which–

    (a)are of a type specified in column 1 of that Table, and

    (b)comply with the relevant installation, alignment and performance requirements set out in the Schedule or Part of a Schedule shown against that type in column 2 of that Table
     
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  9. Triumphal385

    Triumphal385 Active Member

    Mar 23, 2020
    134
    43
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    Absolutely! Nice confirmation.

    If you then look at the Table, column one, the relevant category is solo motor bicycle or combination, and column 2, states the relevant Schedule, is Schedule 4, Part 1.

    That's what I referred to, without actually pasting the legislation. i.e.
    From 18 (2) (a), you refer to solo motorcycle, then see that column 2 as required by 18 (2)(b), states the Schedule to comply with is Schedule 4, Part 1.

    The next thing, is to read the relevant requirements of Schedule 4, Part 1, which I also referred to.

    As your comment agrees with the first part of my point, I'm afraid I can't quite see what your post is meant to add.

    Are you able to clarify, please? Thanks.
     
  10. Notso

    Notso Senior Member

    Dec 17, 2018
    626
    243
    Solihull
    Ah, I missed the motorbike exemption so thought you meant the schedule wasn't obliging the marking.
     
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  11. Triumphal385

    Triumphal385 Active Member

    Mar 23, 2020
    134
    43
    South East
    No worries. I'm getting email rejections from the [email protected] address, so I'll try customer services, instead.

    If DVSA were open, as to why, referring to specific legislation, then compliance would be obvious. However, they like to hide their reasoning, I believe on the basis, that if the public don't know why DVSA do things, then they don't know that DVSA are doing them wrong! That methodology, lets multiple acts of incompetence, pass undetected, to the detriment of society.

    They can be correct, but usually, that's when they provide supporting documentation, from the start.

    Having spent out last summer, for 3 Phillips LED bulbs with ballast packs, then paid for professional alignment, on my Sprint ST 1050, I'm motivated to challenge this new requirement. If I must, I'll return to crappy halogen bulbs, but if I can keep the safer, eco-friendly LED conversions, I will.
     
  12. Triumphal385

    Triumphal385 Active Member

    Mar 23, 2020
    134
    43
    South East
    #51 Triumphal385, Jan 23, 2021
    Last edited: Jan 23, 2021
    Many thanks for that info. I'll try that.

    I've double checked my findings and still cannot find anything to make the LED conversions illegal or if correctly aligned, a reason to fail MoT.

    Let's see what they say.
     
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  13. Triumphal385

    Triumphal385 Active Member

    Mar 23, 2020
    134
    43
    South East
    Just in, from DVSA,

    Good morning


    Thank you for your enquiry regarding LED headlamp bulbs.


    MOT test standards are based on the legal requirements.


    In respect of LED headlamp bulbs, these are not approved for road use and are therefore not legal in themselves.


    It is not illegal to sell these bulbs for off-road use and trustworthy sellers should mention that they are not road legal.


    Here is a link to an independent website which provides more detail: https://www.autobulbsdirect.co.uk/blog/are-led-headlights-legal-in-the-uk/


    There are regular H7, H4 etc bulbs on the market that are twice as bright as standard bulbs and are approved for road use.


    Best regards


    Typically, they refuse to accept that they are wrong and have made a mistake.
     
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  14. Notso

    Notso Senior Member

    Dec 17, 2018
    626
    243
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    So they are saying the bulbs themselves are not approved rather than the lamp that they are put in? When I read it before it looked like in Regulation 12 that you only needed approved bulbs when the lamp required an approval mark.
     
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  15. Triumphal385

    Triumphal385 Active Member

    Mar 23, 2020
    134
    43
    South East
    This was my email to them,

    Dear Sir,

    I own an older Triumph motorcycle and due to the subjectively inefficient headlights, which are a notorious design defect, last summer fitted high quality LED conversion bulbs with ballast packs, costing £420, plus professional alignment fee.

    They improved the quality of light considerably, increasing safety on night riding, without causing dazzle, having been professionally aligned.

    I have recently learned, that you have just amended 4.1.4, of the MoT test requirements, ordering testers to fail all aftermarket LED headlamp conversions.

    Please correct me if I'm wrong, but the relevant legislation is RVLR 1989.

    Reg 18, requires compliance with Schedule 4, Part 1. For solo motor bicycles exceeding 250cc, Sch. 4 Part 1, Para. 5 (d), states there in No Requirement, for a solo motor bicycle to have an approval mark or British Standard mark, on dipped headlamps.

    With physical position as manufactured and the light beam professionally adjusted to comply with MoT requirements, the only other matter in issue, is wattage.

    My bulbs are 4000 Lumens, drawing 25 Watts. They exceed the 24 Watt requirement at para. 8(e), of Sch 4, Part 1.


    Can you please explain, under what legislation, you are now requiring testers to fail my headlamps, which comply with RVLR 1989 and are a safety improvement to the original equipment?

    Also, given that the DVSA framework agreement, declares the main responsibilities of DVSA include improvement of road safety, why has DVSA chosen to insist, that responsibly fitted and professionally aligned LED safety improvements to headlamps on motorcycles, must be failed by testers, when the machine is presented for test? The requirement flies in the face of a primary objective of DVSA.


    If you agree that the correct legislation is RVLR 1989, will you please withdraw the new requirement for LED conversions to be failed, absolutely?

    I am sure there must be some purpose to the new requirement and that a revisit of the methodology can achieve that aim, without punishing responsible owners and reducing road safety.


    Thank you for your time and I look forward to your reply.

    Yours sincerely,

    --------

    Schedule 4, Part 1 is very clear, that there is no requirement for approval marks on headlamps fitted to solo motor bicycles.

    Headlamp as defined in Reg. 3, includes housing unit and bulb.

    Reg 12 relates to the movement of lamps and reflectors, whilst Reg 14, relates only to filament lamps.
    The term filament lamp is not defined in Reg. 3. The Oxford dictionary defines filament as, a conducting wire or thread with a high melting point, forming part of an electric bulb or thermionic valve and heated or made incandescent by an electric current. LED lamps, are not filament lamps, so Reg. 14 cannot apply.

    That only leaves Reg 18, defined under Sch. 4, Part 1.

    In summary, DVSA are wrong. However, they refuse to acknowledge that fact, or the law (RVLR), without being able to justify, other than using the website of a bulb retailer's advice, as grounds for their draconian stance, unsupported by the law. It's a stance, known as cognitive dissonance. Ego not acknowledging reality. e.g. Tony Blair, Donald Trump.

    That, sadly, is very typical of DVSA managerial behaviour. It breaches every value and code of conduct that they are supposed to uphold. The behaviour is morally debased.

    I've personally decided to wait until my MoT in August, and see what transpires. It would though, be good to see someone with clout, challenge them in court. Trouble is, those people appear not care.
     
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  16. Triumphal385

    Triumphal385 Active Member

    Mar 23, 2020
    134
    43
    South East
    I tried, but failed.

    I just had to go back to DVSA & press for specifics.

    They confirm RVLR 1989 is the applicable legislation, adding that DfT have chosen to ensure alignment with Directive 2014/45/EU.

    That refers to Category L3e. 168/2013, defines L3e.

    A high powered two wheel vehicle (mine) is Categorised L3e-A3.

    Article 2 of 2014/45/EU, paragraph 1, states the Directive, from 1st January 2022, will apply to vehicles of Categories ...L3e,....

    Even the DfT excuse of alignment with 2014/45/EU, is wrong!

    As DVSA refused to consider withdrawal of the requirement, I contacted DfT, asking Grant Shapps to order his officials to comply with RVLR 1989 & pointed out Article 2, to DVSA.

    Probably marked my card, again, but there is right and wrong. Ordinary peoples lives are impacted by such decisions.

    I'll let you know any developments. Do you get wi-fi in the Tower?
     
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  17. Fourbears

    Fourbears Noble Member

    Dec 8, 2017
    498
    413
    Norfolk
    Well they have just changed it again.... MOT.jpg
     
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  18. Alan Gilbert

    Alan Gilbert Senior Member

    Nov 22, 2018
    302
    113
    Lincolnshire, UK
    Yes - I came across this earlier today on the Tiger Facebook Group. Fantastic news for the original Tiger 1950 owners as the early projectors were worse than useless and I’ve been running an “illegal” HID but no more !!!
     
  19. Pegscraper

    Pegscraper Elite Member

    Jun 12, 2020
    3,015
    800
    Yorkshire
    My Husaberg has passed for the last few years with a HID bulb conversion anyway. This has always been a bit of a grey issue depending on who's doing the test.
     
  20. Triumphal385

    Triumphal385 Active Member

    Mar 23, 2020
    134
    43
    South East
    There is another thread, on LED headlamps, where I posted an update, recently.

    The below, is content in the outcomemI received from DVSA, after multiple efforts to get them to acknowledge fact and truth.
    ----------------
    "Firstly, I am sorry you were given incorrect information in the reply you received from Andrew. The Department for Transport provided guidance on the issue of LED headlamp bulbs in halogen headlamps, we were unaware this information only applied to cars and the information we received was not specific about either cars or motorcycles.


    Therefore, an LED conversion can be legally made to a motorcycle. I would like to thank you for bringing this matter to our attention and I am sorry for any inconvenience this has caused.


    We are in the process of amending the MOT Manual and getting the information out to testers."
    -------------

    They have made good on this assurance, improving road safety and complying with law and the will of Parliament. Credit, where credit is due.
    Honour, is not readily welcome in the Civil Service. It takes great courage on the part of the individual, who will find themselves alone and abandoned, punished for honesty and integrity.
     
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