hi all confused of Manchester hear

ok I have seen the westfield rear view iva photo that shows 100mm separation of the fog light and the running lights rear.

now the confused part can that separation be 100mm below or above not just inboard . ie a radii of 100 mm from running light

now the reason I ask

driving up the motorway following other new cars and there rear lights in no way meet the 100mm inboard figure in most instances most are above or below the rear running light


Description

As I understood it its only 100mm separation from brake light (which of course in a lot of systems is combined with tail lights)
The separation may be listed under distance from side, I believe the interpretation will be 100mm in all directions.
Rear Fog Lamp to Rear Brake Lamp separation distance must be measured between the “illuminating surface” of each lamp. “Illuminating Surface” should be taken to be the area of the “reflector” to the rear of the bulbs.

As far as comparison with type approved cars, there are 100s of things they don't comply with IVA for whatever reason, but sadly that's no argument as to why a non type approved doesn't meet requirements.
The only thing that can be used to assist in IVA is the note 'Where lamps are mounted in a common housing and are “E” marked, the separation criteria should be assumed to be met.'
So if you use a lamp from a type approved car, you can use the above clause.