Side lights

[CRH]

I don’t know whether it’s relevant but at the moment I have a failed steering column module, meaning I have no indicators or high beam, along with lots of warnings such as reduced braking. . However my hazard warning lights still work.

That's one thing going for it

 

[Blackwolf]

The hazard switch appears to be wired directly to the BCM so the SCU plays no part. The other lights are controlled from the SCU over CANbus to the BCM.

 

[landmannnn]

Fairly quick response from engineering to my dealer's aftersales manager:


Both in EU and in GB (UK - excl. NI), lighting requirements are coming from UNECE R48.

And the “parking lights” are optional, meaning that it is not mandatory to provide.

Again, both EU and GB authorities are approving our vehicles as authorities to allow us sell vehicles in these markets, and they do not mandate this function.

Authority for granting type-approvals to vehicles is VCA and not DVSA.

Authority means no duality of rules.

 

[landmannnn]

Fairly quick response from engineering to my dealer's aftersales manager:


Both in EU and in GB (UK - excl. NI), lighting requirements are coming from UNECE R48.

And the “parking lights” are optional, meaning that it is not mandatory to provide.

Again, both EU and GB authorities are approving our vehicles as authorities to allow us sell vehicles in these markets, and they do not mandate this function.

Authority for granting type-approvals to vehicles is VCA and not DVSA.

Authority means no duality of rules.

As a result it does appear case closed.
It would be interesting to click on contact us and ask the VCA why they type approved a vehicle that did not meet the UK Lighting regs and MOT standards.

 

[Blackwolf]

After looking at the VCA website it seems that issues with in-service vehicles is not within their sphere of operations, and their "contact us" process more-or-less eliminates the possibility of making a general enquiry. They do refer this sort of question out to DVSA and IVS to both of which I have already written, DVSA on 06/11/25 and IVS on 07/11/25. Both of these have quoted response times that mean it is unrealistic to expect a reply for some while yet.

If anyone else felt so inclined to raise the issue with them the email addresses are enquiries@DVSA.gov.uk and IVS.ENQUIRIES@dft.gov.uk respectively.

It is also possible to report a safety defect (which I would argue that this is) directly from the page

Vehicle recalls and faults

What to do if your vehicle, vehicle part or accessory is recalled, has a registered fault and how to report serious safety defect you find

www.gov.uk

 

[CountyV8]

To comply you need to see that in righting from the reverent authority .
One party cant just say it does.

 

[Blackwolf]

As a result it does appear case closed.

Closed as far as our dialogue with IA is concerned, they have made their view very clear. It is not closed as far as challenging what appears to be either a misinterpretation of UNECE R48 or a dangerous flaw with the current legislation.

 

[landmannnn]

After looking at the VCA website it seems that issues with in-service vehicles is not within their sphere of operations, and their "contact us" process more-or-less eliminates the possibility of making a general enquiry. They do refer this sort of question out to DVSA and IVS to both of which I have already written, DVSA on 06/11/25 and IVS on 07/11/25. Both of these have quoted response times that mean it is unrealistic to expect a reply for some while yet.

If anyone else felt so inclined to raise the issue with them the email addresses are enquiries@DVSA.gov.uk and IVS.ENQUIRIES@dft.gov.uk respectively.

It is also possible to report a safety defect (which I would argue that this is) directly from the page

Vehicle recalls and faults

What to do if your vehicle, vehicle part or accessory is recalled, has a registered fault and how to report serious safety defect you find

www.gov.uk

Playing devil's advocate, surely the DVSA will respond with "we are not responsible for vehicle type approval, since this vehicle has been type approved by the VCA it is out of our hands"

 

[Blackwolf]

...

It is also possible to report a safety defect (which I would argue that this is) directly from the page

Vehicle recalls and faults

What to do if your vehicle, vehicle part or accessory is recalled, has a registered fault and how to report serious safety defect you find

www.gov.uk

OK, scrub that, the DVSA "report a serious safety defect page" doesn't work! Firstly it rejects practically every non-alphanumeric character as prohibited (such as brackets), and if you do manage to get past that proble and click 'next' you get a "request blocked by our security service" message. Fantastic!

 

[CRH]

OK, scrub that, the DVSA "report a serious safety defect page" doesn't work! Firstly it rejects practically every non-alphanumeric character as prohibited (such as brackets), and if you do manage to get past that proble and click 'next' you get a "request blocked by our security service" message. Fantastic!

Is that because of how your computer is set up, I didn't complete it but could get to where it was asking about the last service & dealer. It did seem to be as though the problem was new and not a vehicle specific, rather just my vehicle

 

[Blackwolf]

Quite possibly, I tried again from a computer on a .gov.uk network and it worked. It is still very picky about the characters you can use, but when you submit the form the acknowledgement contains a proper email in case you want "to contact the team".

I suggest that the more of us who report a safety concern by this method the more likely it is that they'll investigate. Para 3.1 of their code of practice (defining a safety issue) perfectly describes the situation.

 

[Blackwolf]

Here's another interesting discovery, the exemptions that allow you to park without lights on a road with a 30 mph limit etc do not apply to goods vehicles with an unladen weight in excess of 1,500 kg, so if you have an N1 type -approved Grenadier or Quartermaster you can't ever legally park it on any public road between sunset and sunrise.

 

[Eric]

Here's another interesting discovery, the exemptions that allow you to park without lights on a road with a 30 mph limit etc do not apply to goods vehicles with an unladen weight in excess of 1,500 kg, so if you have an N1 type -approved Grenadier or Quartermaster you can't ever legally park it on any public road between sunset and sunrise.

I think M1 is also limited to 2500 kg, I sure I've seem something along these lines applying to motorhomes
P.S. Just checked a vehicle over 2500kg can not be parked on the carriageway at night without lights irrespective of the speed limit. ego the Grenadier can't be parked on any public road at night.
It would appear that the police don't enforce this, many Land/ Range Rovers parked on the streets at night in towns.

 

[CRH]

I think M1 is also limited to 2500 kg, I sure I've seem something along these lines applying to motorhomes
P.S. Just checked a vehicle over 2500kg can not be parked on the carriageway at night without lights irrespective of the speed limit. ego the Grenadier can't be parked on any public road at night.
It would appear that the police don't enforce this, many Land/ Range Rovers parked on the streets at night in towns.

Explains how the Grenadier got approved and will pass the MOT, are we just wasting our time now with this and just need to get some additional lights for our own safety?

 

[landmannnn]

Explains how the Grenadier got approved and will pass the MOT, are we just wasting our time now with this and just need to get some additional lights for our own safety?

I hadn't heard of that. Of course that is 2.5T gross weight so will include many vehicles, especially EVs.

What puzzles me is that IA (or their agents) seem to have found this solution.
Most 4x4 manufacturers have had to fit some odd lights so the spare wheel doesn't cover the side lights when the door is open. Also quite a few estate/hatchback car have secondary lights visible when the rear hatch is open.

It terms of pursuing this, it does appear to be a dead end now.

Secondary lights in the bumpers hooked up to Ext1 would be a very easy retrofit.

 

[CRH]

I hadn't heard of that. Of course that is 2.5T gross weight so will include many vehicles, especially EVs.

What puzzles me is that IA (or their agents) seem to have found this solution.
Most 4x4 manufacturers have had to fit some odd lights so the spare wheel doesn't cover the side lights when the door is open. Also quite a few estate/hatchback car have secondary lights visible when the rear hatch is open.

It terms of pursuing this, it does appear to be a dead end now.

Secondary lights in the bumpers hooked up to Ext1 would be a very easy retrofit.

I think a lot of them will be below the 2.5T or a low spec derivative that may or may not be available in UK but potentially could?

I was thinking the same about attaching to the outlets on the roof that I don't currently use, I do use the one on the rear near side as an additional reversing light but I could use any and add additional switches where necessary.

I'm sure most police forces wouldn't bother but I would be wary in North Wales. It was many years ago when my father was done for parking facing on coming traffic without side lights on in North Wales but they seem to be against motorists now so will probably be even more keen to catch you out.

 

[Blackwolf]

An update on case people are wondering. DVSA has acknowledgement my enquiry and referred the matter to their Market Surveillance Unit for investigation. The MSU is apparently extremely busy at present so it is unlikely that I'll hear anything soon but it is reassuring that they are looking into this issue (or non-issue if you're Ineos ).

If and when I hear anything I will update again.

 

[Blackwolf]

I have now received replies from both the Market Surveillance Unit (MSU) at VOSA and the International Standards Service (IVS) at the DfT.

The gentleman at the MSU has said the following:

Thank you for your patience while I consulted with colleagues and researched the vehicle.​

Initially, I believed that the parking lights would operate when the ignition is switched off, as this has been the case with every vehicle I have owned over the past forty years. However, after reviewing the relevant lighting regulations, I found no requirement specifying that the parking lights must illuminate without the ignition being engaged. It appears, therefore, that the vehicle meets type approval standards.​

I suggest directing your query to the VCA for further clarification, and I will update you should any additional information become available.​

The view of the MSU is consistent with that of Ineos therefore that there is no enforceable requirement for the obligatory front and rear position lights to work when the ignition is off. I have responded by asking for clarity about the legal situation should someone have no option but to leave a vehicle at the roadside after dark (although realistically I do not expect a legal view from the MSU) but have also asked how it is that at the time that the RVLR were drafted the risk of an unlit vehicle at the roadside was considered so significant that lights were essential yet today, when there is far more traffic and traffic speeds are higher (and headlights have ben weaponised) the risk is no longer considered significant by the EC and consequently the UK. If I get a reply I shall share it here.

The IVS has responded as follows:

Thank you for taking the time to contact the Department for Transport about road vehicle lighting.​

As you highlight there is a difference in the requirements in UNECE Regulation 48 and the Road Vehicles Lighting Regulations 1989 as amended (RVLR). We would like to assure that vehicles that fully comply with UNECE regulation 48 are legal to use on UK roads and based on the information supplied we consider it unlikely that this is a compliance issue, although you have identified that the configuration of the INEOS lighting system is such that you are not able to securely leave the vehicle unattended with the front and rear position lamps activated, which has implications for where you can park the vehicle. However, in such situations where it is necessary to inform other road users of temporary obstruction when the vehicle is at rest it is permissible to utilise the hazard warning device, which according to the published Grenadier owner’s manual remains active when the ignition is deactivated.​

Based on the information supplied we assume that the vehicle was not approved with parking lamp functionality so the paragraphs 6.12 of regulation are not relevant as they are optional lamps and are not fitted to the Grenadier. Unfortunately, page 69 of the published Grenadier owner’s manual suggests otherwise, it may merely be translation error as we believe it should potentially read position lamps / side lights.​

Once again this confirms Ineos's view that the position lamps do not need to operate on a parked vehicle in order for the vehicle to be fully compliant with EC (and hence UK) legislation, however daft that might seem. It is interesting that the IVS comments about the permissibility of using hazard lights rather than position lamps since this, again, is not wholly in accordance with pre-existing UK legislation. This is, I suppose, the result of the EC calling the shots and despite Brexit the UK has failed to keep up.

It would be interesting to know how many other makes of vehicle have the same inability as the Grenadier to illuminate the parking lights - my unscientific survey amongst quite a large number of co-workers who drive about 15 different makes of vehicle has not so far revealed a single case - and it may be that a letter to the senior management in Ineos might be worth a shot. Failing that, just be careful where you leave your Grenadier and keep your fingers crossed that it does not take a terrible and tragic accident involving an unlit Grenadier to sway public opinion.

 

[landmannnn]

Some detailed responses there, they took the time to download the owners manual too.

 

[Eric]

I have now received replies from both the Market Surveillance Unit (MSU) at VOSA and the International Standards Service (IVS) at the DfT.

The gentleman at the MSU has said the following:

Thank you for your patience while I consulted with colleagues and researched the vehicle.​

Initially, I believed that the parking lights would operate when the ignition is switched off, as this has been the case with every vehicle I have owned over the past forty years. However, after reviewing the relevant lighting regulations, I found no requirement specifying that the parking lights must illuminate without the ignition being engaged. It appears, therefore, that the vehicle meets type approval standards.​

I suggest directing your query to the VCA for further clarification, and I will update you should any additional information become available.​

The view of the MSU is consistent with that of Ineos therefore that there is no enforceable requirement for the obligatory front and rear position lights to work when the ignition is off. I have responded by asking for clarity about the legal situation should someone have no option but to leave a vehicle at the roadside after dark (although realistically I do not expect a legal view from the MSU) but have also asked how it is that at the time that the RVLR were drafted the risk of an unlit vehicle at the roadside was considered so significant that lights were essential yet today, when there is far more traffic and traffic speeds are higher (and headlights have ben weaponised) the risk is no longer considered significant by the EC and consequently the UK. If I get a reply I shall share it here.

The IVS has responded as follows:

Thank you for taking the time to contact the Department for Transport about road vehicle lighting.​

As you highlight there is a difference in the requirements in UNECE Regulation 48 and the Road Vehicles Lighting Regulations 1989 as amended (RVLR). We would like to assure that vehicles that fully comply with UNECE regulation 48 are legal to use on UK roads and based on the information supplied we consider it unlikely that this is a compliance issue, although you have identified that the configuration of the INEOS lighting system is such that you are not able to securely leave the vehicle unattended with the front and rear position lamps activated, which has implications for where you can park the vehicle. However, in such situations where it is necessary to inform other road users of temporary obstruction when the vehicle is at rest it is permissible to utilise the hazard warning device, which according to the published Grenadier owner’s manual remains active when the ignition is deactivated.​

Based on the information supplied we assume that the vehicle was not approved with parking lamp functionality so the paragraphs 6.12 of regulation are not relevant as they are optional lamps and are not fitted to the Grenadier. Unfortunately, page 69 of the published Grenadier owner’s manual suggests otherwise, it may merely be translation error as we believe it should potentially read position lamps / side lights.​

Once again this confirms Ineos's view that the position lamps do not need to operate on a parked vehicle in order for the vehicle to be fully compliant with EC (and hence UK) legislation, however daft that might seem. It is interesting that the IVS comments about the permissibility of using hazard lights rather than position lamps since this, again, is not wholly in accordance with pre-existing UK legislation. This is, I suppose, the result of the EC calling the shots and despite Brexit the UK has failed to keep up.

It would be interesting to know how many other makes of vehicle have the same inability as the Grenadier to illuminate the parking lights - my unscientific survey amongst quite a large number of co-workers who drive about 15 different makes of vehicle has not so far revealed a single case - and it may be that a letter to the senior management in Ineos might be worth a shot. Failing that, just be careful where you leave your Grenadier and keep your fingers crossed that it does not take a terrible and tragic accident involving an unlit Grenadier to sway public opinion.

One possible solution may be to install a front and rear parking light ( mounted in the bumpers) using the ext1 tail under the bonnet, if not already used. The draw back would be the excess current draw by leaving the overhead power switch on.