Lighting specialist OSRAM has highlighted a regulatory conflict in the UK regarding LED retrofit bulbs. While factory-fitted LED units are fully road legal, aftermarket LED retrofits are generally restricted to off-road use or vehicles registered before April 1986.
Regulatory Contradictions
The NIGHT BREAKER LED SMART ECE H11 and C5W ECE are the first LED retrofits to achieve UN ECE R37 homologation. Although the Road Vehicles Lighting Regulations 1989 permits ECE R37 bulbs, the current MOT inspection manual states:
“Existing halogen headlamp units on vehicles first used on or after 1 April 1986 must 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 for light source and lamp not compatible.”
Addressing Glare and Performance
OSRAM notes that the NIGHT BREAKER LED SMART delivers 6000 Kelvin white light with up to 50% less glare than the legally permissible maximum. Terri Clark, Lighting Marketing Manager at OSRAM, commented:
“There is also the misconception that LED bulbs are responsible for headlight glare on the roads, however, the most common causes are due to inconsiderate drivers not dipping from high to low beam, misaligned bulbs, poor quality headlight and auxiliary bulbs or drivers fitting cheap, poor quality, illegal, non ECE approved LED bulbs to vehicles that are not designed for them.”
The company is currently working with the Department for Transport to align MOT wording with modern technology. Compared to halogen, these LEDs consume up to 80% less energy and last up to six times longer.




