LED Headlight retrofit - is it possible?

One thing I would say. If you get a finicky MOT tester they will fail the lights as they may deem that washers are required.

Don’t shoot me over this but is something I have experienced. I fitted some Vw oem HID projector lights into a mk6 golf and my car was failed.
Took the car to my now regular MOT who passed the lights (also advising he sees lights where people fit HID diy kits into reflector headlights which he fails), he advised they were very good cut off and autoleveling.

He did say as I didn’t have washers then he couldn’t fail it. It’s the way you interpret the laws.

4. Lamps, reflectors and electrical equipment - MOT inspection manual: cars and passenger vehicles - Guidance - GOV.UK
 
One thing I would say. If you get a finicky MOT tester they will fail the lights as they may deem that washers are required.

Don’t shoot me over this but is something I have experienced. I fitted some Vw oem HID projector lights into a mk6 golf and my car was failed.
Took the car to my now regular MOT who passed the lights (also advising he sees lights where people fit HID diy kits into reflector headlights which he fails), he advised they were very good cut off and autoleveling.

He did say as I didn’t have washers then he couldn’t fail it. It’s the way you interpret the laws.

4. Lamps, reflectors and electrical equipment - MOT inspection manual: cars and passenger vehicles - Guidance - GOV.UK
Some of the early T6s with factory LED headlights didn't have washers so it isn't a requirement for MOT on the T6, you only need self levelling to be legal and MOT compliant. That may not be the case for all makes and models of vehicles, but it is the case for T6 and T6.1. Also, the new T6.1 with factory LED headlights have no washers.
 
I’m agreeing with you. It’s not a requirement. But some MOT testers don’t know the rules. It’s their interpretation of the above rule.
 
Some of the early T6s with factory LED headlights didn't have washers so it isn't a requirement for MOT on the T6, you only need self levelling to be legal and MOT compliant. That may not be the case for all makes and models of vehicles, but it is the case for T6 and T6.1. Also, the new T6.1 with factory LED headlights have no washers.
I’m agreeing with you. It’s not a requirement. But some MOT testers don’t know the rules. It’s their interpretation of the above rule.

As regards MOTs then HIDs need to have the washers, LED lights do not.
Also any aftermarket HID kit is (or should be) a reason to fail MOT.
 
I disagree with you from a MOT testing standpoint.

if washers are fitted they have to work to pass an MOT but washers don’t need to fitted to HID to pass a MOT.

4.1.6. Headlamp cleaning devices
You must inspect vehicles first used on or after 1 September 2009 equipped with headlamp washers.

You can identify HID headlamps from:

  • ‘DCR’ mark on the headlamp lens or body
  • an igniter module or inverter behind the headlamp
  • taking a few seconds to reach full intensity
  • a bluish tinge to the light
HID headlamps use high voltage. You should take care when inspecting these headlamps.


DefectCategory
(a) Headlamp cleaning device:

(i) inoperative
(ii) inoperative in the case of LED or gas discharge systems (HID)
Also LED and HID are treated the same IF washers are fitted.

From a legal view you are correct (I stand corrected) new legislation came in on May this year to clarify the point of HID/xenon.

Legally you now need to fit levelling and washers for HID bulbs into a projector type
Lens.
see here
Aftermarket HID Headlamps

I’d also note that LED is not mentioned in this new legislation.

HID headlamp unit requirements
Therefore a HID headlamp unit sold in the aftermarket should:

  • be type approved to ECE Regulation 98 as a component
  • when fitted to the vehicle should enable ECERegulation 48 to be complied with (although no government inspection will take place)
  • comply with RVLR as far as “use” is concerned
In practice this means:

  • the headlamp unit (outer lens, reflector, bulb) shall be type approved to ECE 98 and be “e-marked” to demonstrate this. That can only be done by the headlamp supplier - Hella, Valeo, etc - who must test the headlamp in an independent laboratory
  • once fitted to the vehicle it must have headlamp cleaning and self-levelling (which can be for the headlamp or can be in the vehicle suspension - some expensive estate cars have “self-levelling suspension” and that is adequate). Also the dipped beam must stay on with the main beam
  • the headlamp must be maintained in good working order, kept clean, and aligned/adjusted correctly in the same way as any other headlamp
Under the Road Traffic Act 1988 it is an offence to supply, fit or use vehicle parts which are not legal.

In summary: it is not permitted to convert an existing halogen headlamp unit for use with HIDbulbs. The entire headlamp unit must be replaced with one designed and approved for use with HIDbulbs and it must be installed in accordance with the rules stated above.
 
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As @Skyliner33 put above and shown in the documents you’ve quoted, HIDs have to have washers, LEDs do not (unless above a luminanc threshold that most manufacturers avoid). It’s also correct that all the aftermarket HIDs are illegal as none of them are approved for use as a whole unit. The only exception would be if you fitted a full OEM xenon light from a T5 or Golf and somehow butchered your front end to fit.
 
Valeo LED units are below 2000 lumens. Found this info in the 2020 UK lighting regs. In contrast, xenon lights are above 2000 lumens so do need leveling and washers. Lots of new cars are appearing with LED headlights without washers from the factory.
Any add in HID or LED aftermarket modules for HEADLIGHTS (no mention of tail lights yet) are now not allowed in recent MOT regs. The best way to be safe is to fit a genuine LED retrofit kit using the talented @Robert and @Pauly guides in the huge T6 LED Headlight retrofit thread.

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