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16 may 2022

LED and Law - part 3: R10 – R65 – R112 – and more

MobiLED occasionally receives questions about the legally permissible application of LED lighting on vehicles.  We have explained this for you in the blog series LED and Law.

This blog is about the various R certificate numbers and what they mean. We can be brief and long about what is permitted and what isn't.


In a nutshell...

-Vehicle lighting must have EU type approval. Lights without this approval may however be used as work lights.
-LED replacement headlights may not be used on public roads because they cannot receive EU type approval. The police can issue a fine even though the light pattern of the lamp passes the MOT.
-Lamps which have the same function must be mounted symmetrically in an even number.


In longhand...

That's nice, the short summary, but what is it based on? In part 2 of the LED and law blog series, we gave an overview of 31 regulations relating to vehicle lighting (click herefor the overview). We will go into that in more detail. Most of the regulations are about technical requirements for a lamp. But there is also a regulation that deals with installation requirements: R48. And the Dutch regulation Visual and Sound Signals 2009 determines who may use warning lights and where they should be installed.


R10: electromagnetic compatibility


An R10 certified lamp indicates that it does not interfere too much with other equipment in the vicinity and that the lamp itself is not interfered with by equipment in the vicinity. Lamps must be R10 certified when used on public roads. But a worklight which can only be used when loading and unloading does not need to have R10 certification. That is, if the lamp can really only be used when the vehicle is stationary.


R37: Replacement headlight bulbs

Replacement headlight bulbs must comply with standards regarding safety, water resistance and the prevention of short circuits. These standards are based on the incandescent and halogen lamp of the past. LED replacement headlights cannot meet these standards because they do not contain a filament. Therefore, they do not receive R37 certification and are officially not allowed to be used on public roads. In the event of an inspection, drivers can be fined by the police for using uncertified parts despite the fact that the light pattern of the lamp does pass the MOT.R37


R112: Headlamps with symmetrical low/high beam

High-beam headlamps and auxiliary headlamps with R112 certification may be used on public roads. They fulfil technical requirements such as minimum and maximum light output, breakability of the lens, heat resistance, etc. After approval, the manufacturer must mark the lamp with "R112" and a reference number between 7.5 and 50. This is the maximum luminous intensity in candela at a distance of 25 metres divided by 4,300. This number is important for calculating the total luminous intensity of all main-beam headlamps on the vehicle.


R148, R149, R150: Uniform requirements

The UN working group IWG SLR is working on simplifying the regulations. This has been detailed in R148, R149 and R150. These regulations are still for information purposes but will eventually legally replace a number of regulations.


R48: Installation of lighting and light-signalling devices

R48 deals with the installation of lamps on passenger cars, commercial vehicles and trailers. A few important details are listed here:


All lights installed on a vehicle must have an homologation (§5.30). However, a lamp is considered not to be present when it cannot be activated by the mere fitting of a light source and/or a fuse (§5.22).

Luminous intensity of headlamps

The total luminous intensity of all driving lamps shall not exceed 430 000 candelas. This corresponds to the reference value 100 (§ In other words, the reference numbers marked on the headlamps when added up may not exceed 100. A reference number of 10 must be given to any headlamp marked R or CR (§


Lamps constituting a pair must be fitted to the vehicle symmetrically. This means that they are symmetrical in relation to the median longitudinal plane of the vehicle based on the exterior geometrical form of the lamp (§5.5.1) and symmetrical in relation to each other (§5.5.2). If you thought that was it, you are out of luck, because lights in the shape of a band must have an even number, extend to at least 40 cm from the extreme outer edge of the vehicle and be at least 80 cm long (§


Not to mention the positioning of direction indicators, the number of brake lights, the electrical connection of tail lights, the orientation of marker lights and the adaptive headlight system. Are you still here?

For the exact requirements, see these paragraphs of Regulation No. 48

Tail light



Manoeuvring light


Reversing light



Marker lighting front tail


Clearance light



Marker lighting side


Comfort light



Fog tail light


Daytime running light



Fog head light


Corner light



Emergency stop signal


License plate light



Striking marker light


Head light low beam



Parking light


Head light high beam




§6.14 t/m §6.17

Head light system adaptive



Brake light





Turn signal

§6.5 en §6.6


R65: Special warning lights

A special warning light emits blue (B), red (R) or amber (A) light and can flash (X) or turn (T). It has one or two intensities. Flashing beams with two or more light sources that emit light around their vertical axis (MD) also qualify as special warning lights. R65 describes standards to which the warning light must comply, such as light colour, brightness, flash frequency, mounting and water resistance. It does not contain any standards for installation; these can be found in the Dutch 2009 Optical and Sound Signals Regulations.

This is an example of an R65 inscription of a beacon lamp (T) with blue light (B) that has 1 light intensity. The lamp has been approved in the Netherlands (E4) with certificate number 002439. The first two zeros indicate the approval was granted according to the requirements of the original version of the regulation R65 (version 00).

This is an example of an R65 inscription of a flash (X) with amber light (A) that has 2 light intensities. The light is approved in France (E2) with certificate number 002442. The direction of the arrow indicates the side of the vehicle where the flash is to be mounted. It is the direction where the light radiates wide.


Dutch Regulations on Optical and Sound Signals 2009

Services and emergency services (Article 1) may use flashing lights and flashing beacons when carrying out urgent tasks (Article 2). If there is a risk of vehicles not being noticed in time by other traffic when carrying out certain tasks, they may use yellow warning lights (Article 6). The set of yellow signal lights must be mounted so that the signal can be seen around the vehicle from 20 metres at 1.5 metres above the road surface (article 5). The warning lights must be R65 certified. The picture below shows a correct installation.

Source in Dutch: https://wetten.overheid.nl/BWBR0025357/2021-01-05

Installation warning light

In the next LED and Law blog, more will be explained about APK inspection requirements for lighting.



This document is intended to provide our customers and other interested parties with an overview of Dutch and European legislation and rules on vehicle lighting. The text has been carefully prepared but is not necessarily complete or exhaustive. There may be changes in the law that are not included in this document. Therefore, no rights can be derived from this text.

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