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I find this interesting as what you are saying countermands this:-
"The invoice must clearly describe the changes made to the vehicle; we need to know what has been changed and how this change meets UK compliance. A statement such as "changed headlights" is not sufficient evidence that, for
example, the original vehicle headlights have been removed and new, full UK specification left-dipping headlights have been fitted to the vehicle.
Where an item is fitted, as standard, suitable for the United Kingdom the garage evidence must make clear that the item is standard and how it is standard (e.g. the vehicle has rear-fog lights fitted as standard on both the rear left and right of the vehicle).
Please note that we do not accept an MOT certificate"

It would be very useful if you could give an example of the wording used on your declaration that resulted in a VCA being issued, so that those that come in the future know what is possible, and how to do it.
This is the content I used without a hitch, gave it to the garage to copy and paste onto their letterhead. I had N+B fit a UK market speedo and UK lights, the vehicle is LHD:-
Inspection of new 2015 Motor Home
Manufacturer: - Niesmann & Bischoff
Model: - Flair 920LF
Base Chassis: - Iveco Chassis
VIN Number: - #

In accordance with the VCA notes and having inspected the above vehicle we can confirm the following:-

· We inspected the headlamps and confirm they are UK specification (headlight beam dips to the left) and are original factory fitted UK specification headlights (dipping left) as standard.

· We inspected the speedometer fitted and it indicates speed in both miles per hour and kilometres per hour, it is a factory fitted UK market speedometer and is dual marked as standard.

· We inspected the rear fog light as fitted and they conform to United Kingdom specifications. Dual rear-fog lights are fitted, one on the rear left and one on the rear right of the vehicle as standard.
 
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