Reading the advice paper, the addition of LED bulbs to the regulations for testing HID bulbs is to close the technical loophole which left LED bulbs unregulated. Now they are regulated to the same level as HID bulbs. It is the fine print on the regulations for HID bulbs which needs scrutiny. Having looked at it the wording seems to allow two of the three conditions to be
legally sidestepped.
Firstly the cast iron condition is the need to have headlamp washers for any bulb system other than incandescent bulbs. Not insurmountable, even if your model didn't have them fitted, higher spec models did and these can be retro-fitted.
The two questionable conditions are the lamp housing and the ability to adjust the height of the beam. For many years owners of all manner of marques believed that this requirement related to self levelling headlights to avoid blinding oncoming drivers because that is what brand new cars had. Close reading of the guidance notes shows that the need is not for self levelling lights but merely lights whose beam level can be adjusted by the driver without leaving the driving seat. Many Volvos have this ability and those that do not may also be able to retrofit manual levelling systems using genuine Volvo parts. In fact the notes go further to absolve the tester from searching for evidence that will confirm that a factory fitted self levelling light system actually works!
That only leaves the lamp housing and here there are strict rules that the housing must be a projector lens system which will not scatter blinding light.
The notes go further and advise the tester how to confirm that the lamp housing is approved if he is in any doubt. However, most MoT testers can identify a projection lens housing when they see one and so do not need to seek any additional indication that their judgement is correct.
So condition one is solidly OK, condition two is also solid if the car has cabin adjustable beam height adjusters. Condition three may be down to whether the tester is confident in his judgement, can find nothing else wrong with the light system and isn't a full blown jobsworth. I know that my Peugeot 406 V6 Coupe by Pininfarina had abysmal lights but it did have headlight washers, manual beam level adjusters operable from the cabin and projection lenses on the dipped beams. I uprated the lighting to HID and never had a failure in the MoT. In fact the original lights were so bad, to the point of being dangerous on a performance car, that I was prepared to remove the HID system for testing and then replace it as I valued my life more than an infringement of the rules. However, it was never necessary and I suspect that the same will apply to all Volvos with projector lamp housings.
You have to read the guidance notes very carefully on this subject and not jump to conclusions as to what they say even if what they say isn't what the legal drafters had in mind when they wrote them!
