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In 2021, the Driver & Vehicle Standards Agency confirmed that ‘Vehicles first used before 1st April 1986 are not required to use type-approved ‘E’ marked headlamps. Therefore, converting a halogen, or other headlamps on such a vehicle to use LED bulbs would not be in contravention of the regulations.’ Hence, LED headlamp bulbs can be fitted to cars first used pre 1st April 1986 and should not impact an MOT test where required, currently for vehicles built or first registered less than 40 years ago.
Conversely, a vehicle first used after 1st April 1986 may fail an MOT for ’ light source and lamp not compatible’ if its headlamps have been converted to LED operation, on the grounds the MoT manual states in relation to vehicles of this age ‘Existing halogen headlamp units should not be converted to be used with high-intensity discharge (HID) or light-emitting diode (LED) bulbs. If such a conversion has been done, you must fail the headlamp.’