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Bulls Bars / winch-less steel bumpers....lets discuss


Chris85

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So, im sure this topic has been discussed many-a-time but upon checking the JOC Forums Im unable to find such a topic. Google also seems to throw up every possible answer without any definitive solution so I thought id ask here.

 

Steel Bumpers (such as the Smittybilt XRC Gen 2). Are they legal or illegal to have installed WITHOUT a winch. I say this specifically 'without' a winch as I currently have the aforementioned bumper sat in my shed ready for install but have yet to get round to ordering a winch.

 

Upon checking online forums, official GOV websites etc I cannot find any definitive document that says yes or no to the question of "Are steel bumpers without a winch road legal".

 

Now, I appreciate that all retailers of such bumpers will sell them with warning notices of 'For Off Road Use Only' which I have identified as a legal requirement of the seller, but in terms of the matter of MOT and Police, does anyone have anything to suggest an answer? (To put this into perspective, im ex police and having asked a few old colleagues of mine, they are also unsure of the answer).

 

So, I open to the floor and appreciate your feedback.

 

Chris 

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When I ordered and fitted my winch bumper (ARB) it was specifically designed and described as such. I had every intention of fitting a winch and did so. There has never been an issue or query when presented for it's annual MOT.

As to whether there would be a problem if a winch was no longer installed I do not know.

So, just fit a winch, old scrap, second hand, it doesn't have to work, it's not a testable item. Make one out of lego or meccano, put a cover on it, they won't notice!

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7 minutes ago, jerryg said:

When I ordered and fitted my winch bumper (ARB) it was specifically designed and described as such. I had every intention of fitting a winch and did so. There has never been an issue or query when presented for it's annual MOT.

As to whether there would be a problem if a winch was no longer installed I do not know.

So, just fit a winch, old scrap, second hand, it doesn't have to work, it's not a testable item. Make one out of lego or meccano, put a cover on it, they won't notice!

Thanks Jerry.

 

Ive been looking into this more and scanning forums online. Found a very interesting debate on an L200 forum.

http://www.l200forum.com/t241241f38-Winch-Bumper-Legality-Law-types-needed.html#no_permission_userprofile

 

Would seem that as long as its not got spikes or flamethrowers coming out of it then its fine!

 

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Hi Chris, You might like to look at the following posts  ''Aftermarket Wrangler Bumpers''. 

Hope this helps.

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I get the impression this topic comes up regularly on this and other forums, with no definitive conclusions ever reached.  The sense I get is that the powers that be are happy with the ambiguity that exists on the topic.  I often see people put that a winch bumper or winch plate on a bumper is fine if it has a winch fitted, but for the life of me I have never been able to find an official source for these statements.

 

I do note the following statement (from somebody who says they are in the police) from the link you gave (which everyone seems to find when they go to Google on this topic) "...Winch bumpers, A bars spot light bars etc fall under modifications and accessories, absolutely no issue with them if the are E marked, although they are still as lethal...".  The general view is that the reason very aftermarket bumper sold says "offroad use only" is precisely because they are not E marked.  But are they still OK if there is a winch fitted?  Beats me.

 

I think the main concern is not about getting stopped on the road, it is the potential legal consequences if heaven forbid somebody is in a major accident and somebody is seriously hurt or the cost of repairing all the vehicles is huge.  Will the insurer say that because the bumper / winch plate is illegal insurance is invalidated?  Can they do this even if you have notified them of the after market bumper and provided the make and model and they did not withdraw cover immediately?  Again, beats me.

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3 hours ago, Chris85 said:

So, im sure this topic has been discussed many-a-time but upon checking the JOC Forums Im unable to find such a topic. Google also seems to throw up every possible answer without any definitive solution so I thought id ask here.

 

Steel Bumpers (such as the Smittybilt XRC Gen 2). Are they legal or illegal to have installed WITHOUT a winch. I say this specifically 'without' a winch as I currently have the aforementioned bumper sat in my shed ready for install but have yet to get round to ordering a winch.

 

Upon checking online forums, official GOV websites etc I cannot find any definitive document that says yes or no to the question of "Are steel bumpers without a winch road legal".

 

Now, I appreciate that all retailers of such bumpers will sell them with warning notices of 'For Off Road Use Only' which I have identified as a legal requirement of the seller, but in terms of the matter of MOT and Police, does anyone have anything to suggest an answer? (To put this into perspective, im ex police and having asked a few old colleagues of mine, they are also unsure of the answer).

 

So, I open to the floor and appreciate your feedback.

 

Chris 

Just looked at a picture of that bumper online.  Surely those shackle mounts projecting in front of the main body of the bumper make it a 'no' from a legal perspective?

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1 hour ago, doodle said:

Had this one fitted for nigh on 8 years- touch wood no issues with either po po or MOT

37743858_10156763207016122_5395146168420270080_n.jpg

And insurers happy with it?

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Had this bumper on my jk for years with no problems from mot/police,but was always in the back of my mind what if I had an accident.

79752FE0-9874-445B-87AC-5D6989F90EAB.png

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3 minutes ago, Tony said:

Had this bumper on my jk for years with no problems from mot/police,but was always in the back of my mind what if I had an accident.

79752FE0-9874-445B-87AC-5D6989F90EAB.png

I really do think MOT pass is a red herring, as far as I understand it is not an MOT item.  You could have an AK47 sitting on your back seat and pass your MOT, wouldn't make the AK47 legal 🤣

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I think the crucial point here is whether it is actually attached to the vehicle. The AK47 clearly isn't and therefore presents no risk, from a moving vehicle point of view. But bull bars/winch bumpers etc are so do they present an additional risk, over the fact that a 1 ton + lump of metal stock from factory presents a risk to others. It doesn't really matter whether it's a feather pillow or a lump of steel or concrete, if it hits you at 30 + mph it will cause you injury.

As an example, my partners car had a rusty front wing with a small piece of metal sticking out. This would fail the mot because it could cause additional injury if it hit a pedestrian, so I had to fix it. Never mind the half ton of winch bumper and winch attached to my Jeep. The reasoning being that that did not in itself present any more additional risk than the 2 ton of Jeep itself!

My conclusion is that the law is an ass and the 'elf & safety brigade will continue to impose their muddled and impractical dogma on everyone without the application of common sense and joined up thinking.

And I believe the legislation re frontal bars initiated from the EU. So say no more!!!

 

 

 

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40 minutes ago, jerryg said:

I think the crucial point here is whether it is actually attached to the vehicle. The AK47 clearly isn't and therefore presents no risk, from a moving vehicle point of view. But bull bars/winch bumpers etc are so do they present an additional risk, over the fact that a 1 ton + lump of metal stock from factory presents a risk to others. It doesn't really matter whether it's a feather pillow or a lump of steel or concrete, if it hits you at 30 + mph it will cause you injury.

As an example, my partners car had a rusty front wing with a small piece of metal sticking out. This would fail the mot because it could cause additional injury if it hit a pedestrian, so I had to fix it. Never mind the half ton of winch bumper and winch attached to my Jeep. The reasoning being that that did not in itself present any more additional risk than the 2 ton of Jeep itself!

My conclusion is that the law is an ass and the 'elf & safety brigade will continue to impose their muddled and impractical dogma on everyone without the application of common sense and joined up thinking.

And I believe the legislation re frontal bars initiated from the EU. So say no more!!!

 

 

 

That’s a very good point. 
 

there is documentation on the gov.uk site regarding BullBars, stating they are legal so that’s something. 
The fact that this is such a muddy subject matter, with no clear definitive answer suggests that a level of common sense is used. As long as you don’t have some mad max style bumper with spikes and razor blades you’ll be ok. 
 

I appreciate the response here and levelled discussion. I dare to think the sarcastic responses I would have gotten on the Wrangler UK Facebook forum!

 

thanks again all,

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The other point I missed was whether or not any addition such as winch bumper and winch is a necessity for professional and/or work purposes. ie Forestry folk have a winch, recovery folk have a winch and other attachments, and so on. Other trades/professions may need other 'add ons'. Therefore part of 'tools of my trade' so again as long as not razor wire or 2 metre spikes should be ok?

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Maybe I am too wary on this topic, but I am not sure that just avoiding spikes and razor wire is the answer.  Though that answer seems to vary with the age of the vehicle.  From the thread referenced by DIgger, V said:

"I have had conflicting information on this over the years from official sources. My interpretation so far is as follows:

 

1. Vehicles registered on or after 24 November 2009 must comply with EU type approval regulations concerning frontal protection systems. If the vehicle's bumper has been designed to comply with these regulations it cannot be replaced with a non-type approved part.

 

2. DVSA advised that a winch bumper that provides sufficient additional strength to a vehicle for the purpose of self-recovery winching could be fitted but it must satisfy UK construction and use regulations and be equipped with a winch. Otherwise, it is not a winch bumper. Another DVSA adviser also believed that if a winch required removal of a frontal protection system from a 2009+ vehicle then the replacement winch mount+frontal protection system must be compliant to be legal. My view is that if Jeep UK offer a Mopar winch bumper as a factory fitted option on a brand new vehicle then that bumper is probably OK. If they don't, then perhaps a company like ARB may produce a type approved alternative for the vehicle model. If there is no type approved winch bumper, then the EU says you can't have one."

 

If this is the correct interpretation it would suggest that I would doubt that Smittybilt bumper could be legally added to a post 2009 registered Jeep, as I suspect it is not E marked - but maybe I am wrong.  As stated above, my concern would be not about a discussion with the police about it, but rather the consequences of a major accident.  At the very least I would be declaring the precise make and model of bumper to my insurer and asking for written confirmation of cover with it fitted.

 

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Maybe I am being massively too sensitive on the subject, one UK based retailler will happily sell you this bumper with nothing on the page for the bumper or general terms & conditions about offroad only use, as far as I can see.  Maybe taking a winch trumps everything else.  Or maybe SMittybilt have had these bumpers E Marked.

image.png.63e2a900600e79db87e23045a64d8618.png

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3 hours ago, Tony said:

I think this is called a stinger,probably ok for u.s market.

Even razor wire and spikes are OK for the US market 😂

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spookie the aardvark
On 15/11/2021 at 16:07, Chris85 said:

Thanks Jerry.

 

Ive been looking into this more and scanning forums online. Found a very interesting debate on an L200 forum.

http://www.l200forum.com/t241241f38-Winch-Bumper-Legality-Law-types-needed.html#no_permission_userprofile

 

Would seem that as long as its not got spikes or flamethrowers coming out of it then its fine!

 

This thread has been very interesting to read and as a lot of people have already said the rules are a complete ass.

Having read through the comments on the L200 forum came across this reply that eas interesting to read :


1. The EU legislation distinguishes between a 'bumper' and a 'frontal protection system.' The latter is defined as a separate structure which, 'in addition to the original-equipment bumper is *intended* to protect the *external* surface of the vehicle from damage in the event of a collision.' This includes 'bull-bars' and 'A-bars,' for example.

2. The legislation bans manufacturers (and probably certain other parties) from 'distributing, offering for sale, or selling' such 'frontal protection systems' unless they have been EU-type approved. And, the rules are set up so that it is practically impossible to get such type approval.

3. However, there is nothing preventing someone from owning such a 'frontal protection system,' or installing it on his vehicle. The rules are aimed at manufactures and distributors, not end users. End users cannot be prosecuted.

4. Moreover, the rules don't apply to 'bumpers' and 'winch bumpers', so long as they are not 'intended to protect the external surface of the vehicle from damage in the event of a collision.' In some cases, this may be a bit of a grey area. But, the legislation does define a 'bumper' as 'intended to give protection to a vehicle when involved in a low speed frontal collision with another vehicle.'

So, in simple English, you will have a hard time finding a bull bar in Europe, as a lot of suppliers will be unwilling to sell it to you. However, there is nothing stopping you from installing one, if you happen to come into possession. Moreover, winch bumpers and winch mounts remain perfectly legal to sell and install. This was apparently confirmed in a Q&A by the Department of Transport.

 

So it would seem that it is very much a case of "Thank you EU" and would explain why most after market bumpers ect are listed as "for off road use only" with most makers and distributers knowing they have a snowball in hells chance of ever getting EU Type Approval. The interesting section here is (3).

 

With regards to insurance I am guessing that most insurance companies will either say a straight NOOOOOOOOOOOOOO or hike the premiums to such an extent, and in the event of an accident still find a way not to pay out - I may be wrong .......................... but i don't think so.

 

Sorry guys rant over 😳😳😳💩

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52 minutes ago, spookie the aardvark said:

This thread has been very interesting to read and as a lot of people have already said the rules are a complete ass.

Having read through the comments on the L200 forum came across this reply that eas interesting to read :


1. The EU legislation distinguishes between a 'bumper' and a 'frontal protection system.' The latter is defined as a separate structure which, 'in addition to the original-equipment bumper is *intended* to protect the *external* surface of the vehicle from damage in the event of a collision.' This includes 'bull-bars' and 'A-bars,' for example.

2. The legislation bans manufacturers (and probably certain other parties) from 'distributing, offering for sale, or selling' such 'frontal protection systems' unless they have been EU-type approved. And, the rules are set up so that it is practically impossible to get such type approval.

3. However, there is nothing preventing someone from owning such a 'frontal protection system,' or installing it on his vehicle. The rules are aimed at manufactures and distributors, not end users. End users cannot be prosecuted.

4. Moreover, the rules don't apply to 'bumpers' and 'winch bumpers', so long as they are not 'intended to protect the external surface of the vehicle from damage in the event of a collision.' In some cases, this may be a bit of a grey area. But, the legislation does define a 'bumper' as 'intended to give protection to a vehicle when involved in a low speed frontal collision with another vehicle.'

So, in simple English, you will have a hard time finding a bull bar in Europe, as a lot of suppliers will be unwilling to sell it to you. However, there is nothing stopping you from installing one, if you happen to come into possession. Moreover, winch bumpers and winch mounts remain perfectly legal to sell and install. This was apparently confirmed in a Q&A by the Department of Transport.

 

So it would seem that it is very much a case of "Thank you EU" and would explain why most after market bumpers ect are listed as "for off road use only" with most makers and distributers knowing they have a snowball in hells chance of ever getting EU Type Approval. The interesting section here is (3).

 

With regards to insurance I am guessing that most insurance companies will either say a straight NOOOOOOOOOOOOOO or hike the premiums to such an extent, and in the event of an accident still find a way not to pay out - I may be wrong .......................... but i don't think so.

 

Sorry guys rant over 😳😳😳💩

Mine was on the Jeep when i bought it!  lol

 

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spookie the aardvark
49 minutes ago, doodle said:

Mine was on the Jeep when i bought it!  lol

🤣🤣 Nice one doodle 👍 My understanding of that would one finger up "the man" 🖕🖕🖕🤣🤣

 

Your safe then mate? can't say the same for pedestrians .......................... but hey that is what god gave them eyes for 🤣🤣🤣

 

Up the revolution brother ✊

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15 hours ago, spookie the aardvark said:

This thread has been very interesting to read and as a lot of people have already said the rules are a complete ass.

Having read through the comments on the L200 forum came across this reply that eas interesting to read :


1. The EU legislation distinguishes between a 'bumper' and a 'frontal protection system.' The latter is defined as a separate structure which, 'in addition to the original-equipment bumper is *intended* to protect the *external* surface of the vehicle from damage in the event of a collision.' This includes 'bull-bars' and 'A-bars,' for example.

2. The legislation bans manufacturers (and probably certain other parties) from 'distributing, offering for sale, or selling' such 'frontal protection systems' unless they have been EU-type approved. And, the rules are set up so that it is practically impossible to get such type approval.

3. However, there is nothing preventing someone from owning such a 'frontal protection system,' or installing it on his vehicle. The rules are aimed at manufactures and distributors, not end users. End users cannot be prosecuted.

4. Moreover, the rules don't apply to 'bumpers' and 'winch bumpers', so long as they are not 'intended to protect the external surface of the vehicle from damage in the event of a collision.' In some cases, this may be a bit of a grey area. But, the legislation does define a 'bumper' as 'intended to give protection to a vehicle when involved in a low speed frontal collision with another vehicle.'

So, in simple English, you will have a hard time finding a bull bar in Europe, as a lot of suppliers will be unwilling to sell it to you. However, there is nothing stopping you from installing one, if you happen to come into possession. Moreover, winch bumpers and winch mounts remain perfectly legal to sell and install. This was apparently confirmed in a Q&A by the Department of Transport.

 

So it would seem that it is very much a case of "Thank you EU" and would explain why most after market bumpers ect are listed as "for off road use only" with most makers and distributers knowing they have a snowball in hells chance of ever getting EU Type Approval. The interesting section here is (3).

 

With regards to insurance I am guessing that most insurance companies will either say a straight NOOOOOOOOOOOOOO or hike the premiums to such an extent, and in the event of an accident still find a way not to pay out - I may be wrong .......................... but i don't think so.

 

Sorry guys rant over 😳😳😳💩

This would seem correct. Having spoken with StormJeeps they have advised that none of their JL bumpers (excluding one that they import for special orders) are ECE approved. 
 

I think ultimately this all comes down to individual responsibility and as mentioned above, whether insurance companies will approve the change. 
 

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Thought we had left the EU......so unsure why anything EU is applicable.

 

I would have thought UK legislation and law was far more important than worrying about EU.

 

 

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Yeh, we did leave EU. Trouble is to get a trade deal HM Govn had to agree to keep nearly all existing EU legislation particularly to do with vehicles. Personally I would have told them to get st...ed!  So we haven't really left at all, and don't start me on fishing! But mustn't do politics on here.

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Mustn't do politics, and getting off topic a bit.........but I find myself in complete agreement with the previous two posts. Unfortunately one of the results of the lie of Brexit 😒

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