E-Mark Approval Explained: What E11, R65 and R10 Mean
E mark approval explained: what E11 means, capital E vs small e, ECE R65 beacons, ECE R10 EMC and the R148, R149 and R150 regulations on your lights.
In this guide
An E-mark is a capital E in a circle with a country number, moulded into a vehicle lamp to show it is type-approved to a UNECE regulation. E11 means the UK granted the approval, E1 Germany. The codes beside it show what the lamp is approved as, such as TA for an R65 beacon or S1 for a stop lamp.
This guide explains how to read the markings on a tractor headlamp, beacon, work lamp or rear lamp, the difference between a capital E and a small e, which regulation numbers you will meet and which ones have been replaced by the newer consolidated regulations R148, R149 and R150, and what the function codes on a lens mean.
What an E-Mark Is
An E-mark is the type-approval marking applied to a vehicle lighting product that has been tested and certified against a specific UNECE regulation. The mark shows that the lamp design met the photometric, colour, mechanical and electrical requirements of that regulation when it was approved, and that production is checked for conformity.
The system runs under the UNECE 1958 Agreement on uniform technical prescriptions for vehicles, administered in Geneva. More than 50 countries are contracting parties, including the UK, the EU member states, Japan, Australia and South Africa. An approval issued by one contracting party that applies a regulation is accepted by the others that apply it. A lamp approved in Germany (E1) is recognised in the UK, and a lamp approved in the UK (E11) is recognised in the EU.
The 1958 Agreement is a United Nations treaty, not an EU one. The UK continued as a contracting party after leaving the EU, and the Vehicle Certification Agency (VCA) continues to issue E11 approvals.
Why It Matters on a Tractor
The Road Vehicles Lighting Regulations 1989 (RVLR) require many lamps on road vehicles to carry an approval mark. On vehicles first used from 1 April 1986, that includes dipped-beam headlamps (an approval mark or British Standard mark), direction indicators, stop lamps and end-outline marker lamps. Warning beacons are different: Schedule 16 of the RVLR sets their height (centre at least 1,200 mm above the ground), visibility and colour, but no marking requirement. Our guide to the Road Vehicles Lighting Regulations 1989 sets out which lamps are obligatory on farm vehicles.
How to Read an E-Mark
A full approval marking has up to 4 parts. They are not always laid out in the same order, but they are always there:
- The circle E and country number, for example E11 (UK) or E4 (Netherlands). This identifies the authority that granted the approval.
- The approval number, a string of digits unique to that approval. On many markings it starts with the series of amendments the lamp was approved to (for example “02”).
- The regulation number, shown on some markings with an R, for example “10R-06” for EMC approval to the 06 series of Regulation 10, or “65R” for a beacon.
- The function code, a letter or number group near the mark showing what the lamp is approved as, for example “S1” for a stop lamp or “HCR” for a halogen dipped and main beam headlamp.
A typical rear combination lamp might show a single E-mark with the function codes R, S1, 2a and AR grouped beside it, meaning it is approved as a rear position lamp, stop lamp, rear indicator and reversing lamp. An LED work lamp approved for EMC might show “E11 10R-06” followed by an approval number.
The country number does not tell you where the lamp was made. A lamp made in China can carry an E4 or E11 approval if the Dutch or UK authority granted it after testing. Nor does the country affect legal standing in the UK: an E1, E4 or E11 approval to the same regulation carries the same weight.
ECE Country Codes
Each contracting party has a fixed number. These are the codes you are most likely to see on lighting sold in the UK:
| Code | Country | Code | Country |
|---|---|---|---|
| E1 | Germany | E17 | Finland |
| E2 | France | E18 | Denmark |
| E3 | Italy | E19 | Romania |
| E4 | Netherlands | E20 | Poland |
| E5 | Sweden | E21 | Portugal |
| E6 | Belgium | E22 | Russia |
| E7 | Hungary | E23 | Greece |
| E8 | Czech Republic | E24 | Ireland |
| E9 | Spain | E25 | Croatia |
| E11 | United Kingdom | E26 | Slovenia |
| E12 | Austria | E27 | Slovakia |
| E13 | Luxembourg | E29 | Estonia |
| E14 | Switzerland | E32 | Latvia |
| E16 | Norway | E43 | Japan |
So “E11 meaning” is simple: the approval was granted by the UK authority. It says nothing about quality beyond the fact that the lamp passed the regulation’s tests.
Capital E vs Small e
The capital E in a circle is a UNECE approval under the 1958 Agreement. The small e in a rectangle is an EU approval, granted under EU type-approval directives and regulations by a member state, using broadly the same country numbers (e1 Germany, e4 Netherlands, and so on).
The small e mark is common on lighting for EMC. Many LED work lamps and beacons carry an e-mark for electromagnetic compatibility granted under the EU automotive EMC rules, sometimes alongside an E-mark for the lamp function. Both are genuine approvals. For lighting functions on lamps sold in the UK, the capital E is the one to look for.
The UK stopped granting EU approvals at the end of the Brexit transition period on 31 December 2020, so new e11 approvals are no longer issued. E11 UNECE approvals continue as before.
Marks That Are Not Approvals
- CE is a general product conformity mark. It is not a vehicle lighting approval.
- An E in a circle with no number is not a valid mark.
- DOT or SAE markings are US standards and are not UNECE approvals.
- “E-mark compliant” or “meets ECE standards” in a listing, with no mark on the lamp, means nothing. Look for the mark on the lens or housing.
The UNECE Regulation Numbers Buyers Meet
UNECE lighting regulations are numbered in the order they were adopted. The table below lists the ones you will see on agricultural and vehicle lighting, what each covers, and whether it has been folded into one of the consolidated regulations.
| Regulation | Covers | Status |
|---|---|---|
| R3 | Retro-reflectors (including triangular trailer reflectors) | Consolidated into R150 |
| R4 | Rear registration plate lamps | Consolidated into R148 |
| R6 | Direction indicators | Consolidated into R148 |
| R7 | Front and rear position lamps, stop lamps and end-outline marker lamps | Consolidated into R148 |
| R10 | Electromagnetic compatibility (EMC) of vehicles and electronic components | Separate, current |
| R19 | Front fog lamps | Consolidated into R149 |
| R23 | Reversing lamps | Consolidated into R148 |
| R37 | Filament light sources (bulbs such as H4, H7, P21W) | Separate, current |
| R38 | Rear fog lamps | Consolidated into R148 |
| R48 | Installation of lighting on cars, vans, lorries and their trailers | Separate, current |
| R65 | Special warning lamps (beacons and directional warning lamps) | Separate, current |
| R86 | Installation of lighting on agricultural and forestry tractors | Separate, current |
| R87 | Daytime running lamps | Consolidated into R148 |
| R91 | Side marker lamps | Consolidated into R148 |
| R98 | Headlamps with gas-discharge (xenon) light sources | Consolidated into R149 |
| R112 | Headlamps with an asymmetrical dipped beam (filament or LED) | Consolidated into R149 |
| R113 | Headlamps with a symmetrical dipped beam | Consolidated into R149 |
| R128 | LED light sources | Separate, current |
| R148 | Light-signalling devices (position, stop, indicator, reversing, fog, DRL, side marker, plate lamps) | Consolidated regulation |
| R149 | Road illumination devices (headlamps, front fog, cornering lamps, adaptive lighting) | Consolidated regulation |
| R150 | Retro-reflective devices and markings | Consolidated regulation |
What R148, R149 and R150 Replaced
Under the UNECE lighting simplification work, 3 consolidated regulations took over the content of older device regulations without changing the technical requirements at the time:
- R148 (light-signalling devices) combines R4, R6, R7, R23, R38, R50, R77, R87 and R91.
- R149 (road illumination devices) combines R19, R98, R112, R113, R119 and R123.
- R150 (retro-reflective devices) combines R3, R27, R69, R70 and R104.
The new regulations came into use from 2019, and the old ones were frozen so that new development happens in R148, R149 and R150. Approvals already granted under the old regulations remain valid, which is why lamps on sale today carry a mix of old numbers like R7 and R65 and new ones like R148. Neither is better or worse for the buyer.
R65: Beacons
Regulation 65 covers special warning lamps, which on a farm means amber beacons and directional warning lamps. It was not consolidated and is still the regulation to look for on a beacon. The RVLR do not make R65 approval compulsory for a beacon, but it is the recognised standard for beacon colour and intensity. R65 lamps carry a category code: T for a rotating or stationary flashing lamp and X for a directional flashing lamp, followed by a colour letter, A for amber, B for blue or R for red. So an amber rotating or flashing beacon is marked TA. The class shows whether the lamp has 1 intensity level (Class 1) or 2 levels for day and night use (Class 2). Our guide to ECE R65 beacons covers beacon approvals in more detail.
R10: EMC
Regulation 10 covers electromagnetic compatibility. Any lamp with electronics inside, which means every LED lamp and LED beacon, can interfere with radios, telematics and GPS guidance if it is badly designed. An R10 approval shows the lamp has been tested for radiated interference and immunity. It does not approve the light output, so an LED work lamp with only an R10 mark is EMC-approved, not road-legal as a headlamp or driving lamp. See our guide to EMC compliance for LED lights.
R112, R98 and R149: Headlamps
Headlamps for cars, vans and most tractors were approved to R112 (halogen and LED, asymmetrical dipped beam) or R98 (xenon), with R113 for symmetrical dipped beams. New approvals use R149. The approval applies to the headlamp with the light source category it was designed for, which matters if anyone suggests putting an LED bulb in a halogen headlamp.
Function Codes on the Lens
The function codes beside the E-mark tell you exactly what the lamp is approved to do. A lamp is only approved for the functions shown.
| Code | Function |
|---|---|
| A | Front position lamp (sidelight) |
| R, R1, R2 | Rear position lamp (tail light) |
| S1, S2 | Stop lamp |
| S3 | High-level (centre high-mounted) stop lamp |
| 1, 1a, 1b | Front direction indicator |
| 2a, 2b | Rear direction indicator |
| 5, 6 | Side repeater indicator |
| AR | Reversing lamp |
| F | Rear fog lamp |
| B, F3 | Front fog lamp |
| RL | Daytime running lamp |
| SM1, SM2 | Side marker lamp (SM1 for all vehicles, SM2 for cars only) |
| HC, HR, HCR | Halogen dipped beam, main beam, or both |
| DC, DR, DCR | Gas-discharge (xenon) dipped beam, main beam, or both |
| PL | Plastic lens |
| IA, IIIA | Retro-reflector classes (IIIA is the triangular trailer reflector) |
Headlamp markings also carry a traffic-direction symbol. An arrow means the dipped beam is made for left-hand traffic, as in the UK. A double-headed arrow means it can be switched between left and right. No arrow means right-hand traffic only, which would dazzle oncoming drivers in the UK. A number such as 20 or 30 near a main beam mark is a reference for its intensity.
Matching the Approval to the Job
Check that the approval covers the job the lamp will do on the road. A rear lamp marked R and S1 but not 2a is not approved as an indicator, even if it has an amber section. A work lamp with no headlamp or driving lamp approval should not be used as either on a public road. Our guide to whether LED light bars are road legal explains how this applies to light bars and spot lamps.
What If a Lamp Has No Approval Mark
A lamp without an approval mark is usually sold for off-road or work use only. It may be bright and well made, but it has not been tested for colour, beam pattern or intensity against a UNECE regulation, and it does not meet the RVLR where the regulations require an approval mark for that lamp.
The practical rule for farm vehicles is straightforward:
- Lamps the law requires (headlamps, stop lamps, indicators, rear position lamps and the rest) should carry an approval mark for their function.
- Work lamps do not need a lighting approval as long as they are only used off the road, or for work at the roadside without dazzling anyone. They should be switched off when driving on the road.
- Beacons are not legally required to carry an approval mark, but an R65-approved beacon has tested colour and intensity and is the sensible choice.
- Any LED product on a tractor with GPS guidance or radio telematics is worth buying with R10 EMC approval, whatever its job.
Lamps with no mark at all, or with an unconvincing one, are the ones that cause problems at roadside checks and annual tests on HGVs and trailers.
How to Check Approval Marks on Agricultural Lighting
Checking takes 3 steps: find the mark, read the function codes, and match them to the job.
- Find the mark. It is usually moulded into the lens, often near the edge, or printed on a label on the housing. A torch held at a low angle to the lens shows up moulded markings that are hard to see in daylight.
- Read the country number and approval number. A circle E, a country number and an approval number should all be present. If any are missing, the mark is not valid.
- Read the function codes and regulation numbers. Check they match the lamp’s use: TA and R65 for a beacon, S1 for a stop lamp, HC or HCR for a headlamp, 10R for EMC.
Voltage matters too. A lamp marked 12V should be used on a 12V system, and a 24V lamp on 24V. Multi-voltage LED lamps are usually marked with their range, such as 10 to 30V.
When buying online, check the product listing for the approval and, where possible, the manufacturer’s datasheet. Browse our LED tractor beacons for R65-approved warning lights, or the rear lamp range for E-marked combination lamps.
Frequently asked questions
What does E11 mean on a light?
E11 means the lamp was type-approved by the United Kingdom’s approval authority, the Vehicle Certification Agency. It is accepted in the same way as an approval from any other UNECE contracting party, such as E1 (Germany) or E4 (Netherlands).
What is the difference between an E-mark and an e-mark?
A capital E in a circle is a UNECE approval under the 1958 Agreement. A small e in a rectangle is an EU approval granted under EU type-approval rules. Both are genuine approvals; the small e is often seen on LED lamps for EMC.
What does ECE R65 mean on a beacon?
R65 is the UNECE regulation for special warning lamps. An amber rotating or flashing beacon approved to it is marked TA, with Class 1 for one intensity level or Class 2 for separate day and night levels.
What is ECE R10 approval?
R10 is the UNECE regulation for electromagnetic compatibility. An R10 mark shows an electronic product, such as an LED lamp, has been tested for radio interference and immunity. It does not approve the lamp’s light output for road use.
Are old R7 or R112 approvals still valid now R148 and R149 exist?
Yes. R148, R149 and R150 consolidated the older regulations without changing their technical requirements, and approvals already granted under the old numbers remain valid.
