24 may 2022

LED and Law - part 4: MOT requirements

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

The last blog in this series is about the Dutch MOT handbook. We can be short and long about the Dutch MOT requirements for vehicle lighting.

In a nutshell...

-	You risk being fined by the police if other traffic participants are disturbed by the lighting. This also applies to certified lights.
-	LED replacement headlights may not be used on public roads because it is not possible to get an EU approval. The police can impose a fine even though the light pattern of the lamp passes the MOT.
-	If LED lights on a vehicle can be switched on and off independently, this does not constitute grounds for rejection at the MOT test.

In longhand…

That is nice, that brief summary, but what is it based on? Below is an overview of Dutch MOT requirements that apply to vehicle lighting.

MOT handbook

The Algemene Periodieke Keuring (APK) is a legally required vehicle test in the Netherlands to increase road safety and protect the environment. It is similar to an MOT test in the UK. The APK handbook contains all the requirements that vehicles have to meet. It is based on the Dutch Vehicles Directive.

The APK handbook also contains additional explanations for special cases, such as dynamic rear lights that do not blink but "run". Based on these explanations, the inspector knows what to check. The most up-to-date inspection requirements can be found on the RDW website.

Source in Dutch: https://apk-handboek.rdw.nl

The MOT handbook and the Vehicles Directive distinguish between these vehicle types:

M	Passenger cars and buses: motor vehicles on four or more wheels designed and constructed for the transport of people
N	Company cars: motor vehicles with four or more wheels designed and constructed for the transport of goods
O	Trailers (including semi-trailers)
L	Two- and three-wheeled vehicles: Mopeds, motorbikes, tricycles and quadricycles
T	Wheeled tractors
C	Track-laying tractors
R	Agricultural or forestry trailer
S	Interchangeable towed machines
U	Mobile machinery: motor vehicles specially designed and constructed for the performance of work and not intended for the transport of persons or goods by road

Source in Dutch: RDW website

Dutch MOT requirements 2022 for lighting of passenger cars

Lighting is also checked during the MOT inspection, usually by visual inspection and sometimes by measurement. The standards for lighting differ for each type of vehicle. Below is a summary for passenger car lighting.

Source in Dutch: https://apk-handboek.rdw.nl/personenautos/lichten-lichtsignalen-en-retroreflecterende-voorzieningen

The lights and reflectors must work properly, be securely attached to the vehicle and the lenses are not allowed to be broken. The lighting operation must also work properly. All lights with the same function must have the same intensity and be of the same size (Article 5.2.55). A particular colour is prescribed for each type of lighting (Article 5.2.53 and Article 5.2.59). And finally, everything must be properly tuned (Article 5.2.59b, Article 5.2.61).

In principle, passenger cars must be equipped with (Article 5.2.51):

-	front: 2 high beam headlamps, 2 low beam lights, 2 direction indicators and hazard warning flashers;
-	visible at the front: 2 marker lights;
-	rear: 2 rear lights, 3 brake lights, 2 indicators, hazard warning flashers, 1 licence plate light, 2 red reflectors, 1 rear fog lamp and 1 reversing light;
-	visible at the rear: 2 marker lights.

Exceptions exist depending on the date of first use and the size of the car. Important dates are: 7-1-1967, 12-31-1997, 9-30-2001 and 12-31-2006.

Passenger cars may be equipped with (Article 5.2.57):

-	front: 2 front fog lamps, 2 daytime running lights, multiple high beam headlights (no more than 4 may function simultaneously), 2 auxiliary clearance lights, 2 auxiliary direction indicators and hazard warning flashers, 2 curve lights, 2 cornering lights and white retro-reflectors;
-	visible at the front: 2 additional marking lights;
-	rear: 2 additional rear lamps, 2 additional direction indicators and hazard warning flashers, 1 additional rear fog lamp, 2 lateral position lamps and 2 additional reversing lamps;
-	visible at the rear: 2 additional marker lights;
-	per side: 1 additional direction indicator, 1 manoeuvring light, amber retro-reflectors (the last one may be red) and side marker lamps;
-	working lights and parking lights.

Passenger cars may not be equipped with more than these lights (Article 5.2.65).

It is forbidden for passenger cars to be equipped with (Article 5.2.64 and 5.2.65):

-	blinding lights. Exceptions to this are the main lights, the brake lights, direction indicators and hazard warning lights;
-	flashing lights. Side-marker lamps may flash in sync with the direction indicators;
-	lighting inside the vehicle that radiates to the outside of the vehicle;
-	light fittings for blue lights or even give the impression that there would be blue lights on the car.

Disclaimer

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.