IVA Glass Requirements
The Problem:
Most of the IVA rules are relatively easy to comply with if you bear them in mind as you progress with your build. The vast majority are either sensible (securing wiring, emissions, having seat belt anchorages of adequate strength etc), obvious (having the right number/colour of lights in the right position, having sufficient visibility from within the vehicle etc.), or challenging but understandable (not having sharp ‘projections’ inside or outside the vehicle). However, there is one requirement that is rather more problematic; one that could put off people from building their dream build (or, more likely, push them into ignoring the IVA and any potential registration obligations)…
Section 45 Safety Glass of the IVA manual contains some of the most problematic requirements in the entire document; with the difficulty of achieving compliance being heavily dependent on the era and popularity of car you are basing your build around. In short (ignoring the easy to comply with bits), the section mandates that all ‘glazing’ that contributes to the drivers view out of the vehicle directly ahead, to the sides, or behind must be made from ‘approved materials’. To summarise, the approved materials appear to be as follows:
• Front windscreen – must be E-marked and made of either laminated or toughened glass.
o Laminated – along with the E43R, must be permanently marked with the additional marking II or III
o Toughened – along with the E43R, must be permanently marked with the additional marking I
Note: Although the IVA manual appears to be silent on it, I assume that a toughened windscreen would not be allowed if the vehicle is going to be on a Q-plate (i.e. will not receive an age-related plate), as post 1983 all vehicles had to come with laminated screens. If you only have access to a toughened E-marked screen, you’d be best contacting your local IVA station for specific clarification.
• Rear window – must be E-marked and made from either toughened glass or ‘plastic glazing’ (i.e. Lexan/Polycarbonate).
o Lexan – along with the E43R, must be permanently marked with the additional marking VIII/B/M
o Toughened - must be permanently marked with E43R
• Side Windows– must be E-marked and made from either toughened glass or ‘plastic glazing’ (i.e. Lexan/Polycarbonate).
o Lexan – along with the E43R, must be permanently marked with the additional marking VIII/B
o Toughened - must be permanently marked with E43R
The main issue with these material requirements is that the glass available for many classic cars is not E-marked (the venerable BS mark is the common historic glass standard in the UK and is unfortunately not acceptable under the IVA).
If you have a popular classic that is well served by the aftermarket, you may well be in luck and can read on no further; most newly produced glass that is readily available (i.e. that has been commissioned in volume by a classic spares supplier) will come E-marked off the shelf…but do specifically check with your supplier before you buy.
If you have a classic that was sold in period at volume within mainland Europe, you may also be in luck; many mainland-based component OEM’s applied E-marks to glass years before the UK manufacturers did so (i.e. do some international digging to see what’s available).
If you have a classic that has flat glass, you have an easy (and affordable) solution; there are many companies around the UK that can produce toughened flat E-marked glass panels to a template (a company that we’ve had positive experience with is Caldwells Windows, but others are out there).
However, if you have a classic that is not well-loved in the aftermarket, was never originally supplied with E-marked glass, and utilises curved glass, there are still some potential solutions to the E-mark problem:
Potential Solutions:
Front Windscreen:
1. Cutting down a laminated screen from another car to fit your build: If you can find a suitable E-marked laminated windscreen to work from, it is possible to cut a windscreen intended for a different car down to fit your car. There are many video tutorials online on how to cut laminated glass, but this one is as good as any. The key considerations when selecting a ‘donor’ screen will be the size (it needs to be big enough to cut down to fit your car), the shape (window rubbers are somewhat forgiving, but it needs to be roughly the right curvature), and where the E-mark is (the E-Mark must be retained once your done cutting it down).
• Note: To make checking the curvature of potential ‘donor’ screens easier (without having to lug around your original screen), making horizontal and vertical curvature templates out of ABS sheet would be advisable.
• Note: Some of the best available options may well be the modern reproduced windscreens that are available for the classic cars that are more popular than your car. Escorts, beetles etc. have off-the-shelf E-marked laminated screens available that may better suit the shape of many classics more than modern screens would.
• Note: Some modern rear screens are tempting, as they are often more curved on their sides than modern car windscreens, but as they will be made from toughened glass, they are not suitable for cutting down.
• Note: It’s physically impossible to cut down toughened glass; even if you can find a toughened windscreen with the correct E-Mark, do not attempt it! BANG…
2. Commission a new laminated front windscreen: This is what I ended up doing as Pilkington classics had the correct tooling and were willing to apply the E-mark to a single order at a very reasonable per-screen cost (so reasonable that I ordered two to be safe). However, there are a couple of snags; if they don’t have the tooling for your car it’ll be thousands of pounds to commission one (you can check their list here), and (more worryingly) they seem inconsistent in their approach to E-marking classic screens. When I ordered my windscreens from them they were happy to certify and mark it to the ECE standard, however the last time I spoke to them about another car they stated that there is an administration charge and an MOQ to certify screens that have only previously been BS-marked. The things they are now looking to charge their customer for do not seem to be justified/required under the ECE regulation, so unfortunately this simply comes across as a way for them to make more money…their position on charging for E-mark certification does seem to vary greatly depending on who you speak to at Pilkington, so “you’re mileage may vary”. I am currently investigation a potential alternative in mainland Europe, if this comes to anything I will update this post.
Side Windows:
1. Order polycarbonate windows: As polycarbonate is allowable under the IVA, can be obtained for any car (as the manufacturers can use your originals as templates and formers if they don’t already have templates on hand), and is often very affordable, this is the obvious easy answer for side windows. The best company I found was Plastics For Performance as they are sensibly priced, offer many enhancement options, and can apply proper E-marks to their products (noting many of the other UK-based companies were offering E-Mark stickers that are not allowed under the IVA). Things to consider:
• Consider getting your lexan windows “thermoformed” if they are winding windows (they will then operate in the window channels much like the original glass did)
• Consider getting your Lexan “hard-coated” if they are likely to wear (winding windows) or you want them to be a permanent solution (i.e. you don’t think they will ‘fall off’ after the IVA test).
• Insist to P4P that they use engraving for the E-mark if you have winding “hard-coated” windows, P4P have issues with the marking ink properly adhering to the hard-coat surface (ask me how I found out). If you get them to engraved then print the E-Mark it’ll not be at risk of being scratched off at all.
2. Commission new toughened windows: I went with this option, but in hindsight I would probably still recommend option 1 due to cost. To commission the side glass for my car it cost approximately 2.5x what the hard-coated & thermoformed Lexan would have cost; noting that I’ve ended up with 3 full sets of glass due to MOQ’s (that I may be able to sell to recover some of the cost delta), and I’ve got a far superior and more permanent solution (these will never need to eventually “fall off” after the test). If you do go with this option, I would recommend Safety Glass Industries Ltd (01618770011). SGI have established links into several European glass manufacturers, have been able to obtain small batches of bespoke curved glass, and can arrange all the required CAD drawings. They’re very helpful nice people, but you need to recognise that any single order from a car enthusiast is a small order to them and their Supplier; patience is mandatory.
Rear Window:
1. Order a polycarbonate rear window: This is mostly as per option 1 for the side windows; however, to save some money, it’s not as critical to have the panel ‘thermoformed’ or ‘hard-coated’. The lexan rear screen will form itself reasonably well once it’s in the window rubber (thinner Lexan can be specified to assist with this), and there’s not such a high chance of it scratching (assuming you don’t have a rear wiper). It’s also not as essential to insist on engraving for the E-mark, but I’d recommend it as my first rear screen had to be sent back to be re-worked when the markings were slightly rubbed off by the packaging in transit.
2. Commission a new toughened rear window: Unless your rear window has a continuous curve, or you’ve got more money than you know what to do with, go for option 1. Most rear screens are either compound curves (curved in two planes), have a non-continuous curve (curve-flat-curve), or both; to make such a toughened screen would require a bespoke tool. I had an estimate of £2500 just for the tooling to do my firenza rear screen…I went with Lexan/Polycarbonate.
• NOTE: Although it’s rare for them to have retained tooling for most classic rear screens, it’s always worth asking companies such as Pilkintons; you may get lucky.
General Notes:
• If any commonsense or logic was applied by those writing the rules, the BS Mark would still be allowable under the IVA…but it is not…it sucks, but there you are.
• I’ve seen many threads where people ask whether you can simply go through the IVA test with windows missing; Note 6 within Section 45 specifically precludes this as an easy way out. Put simply, if there is evidence that a window should (or more accurately could) be fitted you will probably fail the test based on a window having been “deliberately removed for the purpose of the test”. So, unless you want to weld up the window channels, remove winder mechanisms etc., it’s a nonstarter for most types of car.
• There appears to be some common confusion around what markings are required for toughened glass side windows. On first reading many (including me) think they need to be marked with VII in addition to the E43R. This is not the case; toughened glass side windows do not need to have the glass ‘type’ appended to the E43R marking. It took me some time to understand the rules on this one (including digging into the ECE regulation itself), but for some easy proof, take wander outside and look at the side window of any ‘modern’.
• Another idea that is often mentioned online is whether an E-mark sticker could simply be applied to the glass. Whether applied by the window manufacturer, or faked by the builder, a sticker will not pass the IVA test. All markings must be ‘permanent’.
• There may be potential creative work arounds for the rear and side (not for windows ‘partly or wholly on either side of the driver’s seat’ though) that may not constitute a fail…for example, I have seen some vehicles that have solid metal panels mounted by a window rubber instead of normal back window…but I’ll not cover such shenanigans here.
• When faced with additional build cost, it may be tempting to fake compliance by counterfeiting the required markings (permanently etching a copy of a real E mark onto a blank windscreen for example). I’d strongly advise against doing this; the IVA examiner only has to ask for a receipt from the manufacturer (which they can do) or check the article registration with the manufacturer to uncover the fraudulent attempt. If such an attempt was uncovered during the test I’m not sure what action would be taken by the authority, but I’d not fancy being in that situation.
Disclaimer:
I’ve elected to build my “radically” altered Vauxhall Firenza to comply with the requirements laid out under the IVA process (LINK). I will be taking my build through the test, I will end up with a Q-plate registration, it has added cost to my build, and I’m fine with it. However, I’m also 100% fine with individual choice…if people choose not to observe the IVA for whatever reason, it’s all good.
Whether you think we’re lucky to have the IVA route as an option in the UK, or you simply want the requirements to go away, this post/thread isn’t intended to ignite another debate on the topic. The intent is to highlight one area where IVA compliance can be troublesome, and to offer up some options that may or may not help people overcome it.
Note: I’m not an IVA expert, everyone should read the manual to understand the rules for themselves before committing any time and money to it. Any further additions or clarifications from those that are more knowledgeable than I will be appreciated/welcomed.
The Problem:
Most of the IVA rules are relatively easy to comply with if you bear them in mind as you progress with your build. The vast majority are either sensible (securing wiring, emissions, having seat belt anchorages of adequate strength etc), obvious (having the right number/colour of lights in the right position, having sufficient visibility from within the vehicle etc.), or challenging but understandable (not having sharp ‘projections’ inside or outside the vehicle). However, there is one requirement that is rather more problematic; one that could put off people from building their dream build (or, more likely, push them into ignoring the IVA and any potential registration obligations)…
Section 45 Safety Glass of the IVA manual contains some of the most problematic requirements in the entire document; with the difficulty of achieving compliance being heavily dependent on the era and popularity of car you are basing your build around. In short (ignoring the easy to comply with bits), the section mandates that all ‘glazing’ that contributes to the drivers view out of the vehicle directly ahead, to the sides, or behind must be made from ‘approved materials’. To summarise, the approved materials appear to be as follows:
• Front windscreen – must be E-marked and made of either laminated or toughened glass.
o Laminated – along with the E43R, must be permanently marked with the additional marking II or III
o Toughened – along with the E43R, must be permanently marked with the additional marking I
Note: Although the IVA manual appears to be silent on it, I assume that a toughened windscreen would not be allowed if the vehicle is going to be on a Q-plate (i.e. will not receive an age-related plate), as post 1983 all vehicles had to come with laminated screens. If you only have access to a toughened E-marked screen, you’d be best contacting your local IVA station for specific clarification.
• Rear window – must be E-marked and made from either toughened glass or ‘plastic glazing’ (i.e. Lexan/Polycarbonate).
o Lexan – along with the E43R, must be permanently marked with the additional marking VIII/B/M
o Toughened - must be permanently marked with E43R
• Side Windows– must be E-marked and made from either toughened glass or ‘plastic glazing’ (i.e. Lexan/Polycarbonate).
o Lexan – along with the E43R, must be permanently marked with the additional marking VIII/B
o Toughened - must be permanently marked with E43R
The main issue with these material requirements is that the glass available for many classic cars is not E-marked (the venerable BS mark is the common historic glass standard in the UK and is unfortunately not acceptable under the IVA).
If you have a popular classic that is well served by the aftermarket, you may well be in luck and can read on no further; most newly produced glass that is readily available (i.e. that has been commissioned in volume by a classic spares supplier) will come E-marked off the shelf…but do specifically check with your supplier before you buy.
If you have a classic that was sold in period at volume within mainland Europe, you may also be in luck; many mainland-based component OEM’s applied E-marks to glass years before the UK manufacturers did so (i.e. do some international digging to see what’s available).
If you have a classic that has flat glass, you have an easy (and affordable) solution; there are many companies around the UK that can produce toughened flat E-marked glass panels to a template (a company that we’ve had positive experience with is Caldwells Windows, but others are out there).
However, if you have a classic that is not well-loved in the aftermarket, was never originally supplied with E-marked glass, and utilises curved glass, there are still some potential solutions to the E-mark problem:
Potential Solutions:
Front Windscreen:
1. Cutting down a laminated screen from another car to fit your build: If you can find a suitable E-marked laminated windscreen to work from, it is possible to cut a windscreen intended for a different car down to fit your car. There are many video tutorials online on how to cut laminated glass, but this one is as good as any. The key considerations when selecting a ‘donor’ screen will be the size (it needs to be big enough to cut down to fit your car), the shape (window rubbers are somewhat forgiving, but it needs to be roughly the right curvature), and where the E-mark is (the E-Mark must be retained once your done cutting it down).
• Note: To make checking the curvature of potential ‘donor’ screens easier (without having to lug around your original screen), making horizontal and vertical curvature templates out of ABS sheet would be advisable.
• Note: Some of the best available options may well be the modern reproduced windscreens that are available for the classic cars that are more popular than your car. Escorts, beetles etc. have off-the-shelf E-marked laminated screens available that may better suit the shape of many classics more than modern screens would.
• Note: Some modern rear screens are tempting, as they are often more curved on their sides than modern car windscreens, but as they will be made from toughened glass, they are not suitable for cutting down.
• Note: It’s physically impossible to cut down toughened glass; even if you can find a toughened windscreen with the correct E-Mark, do not attempt it! BANG…
2. Commission a new laminated front windscreen: This is what I ended up doing as Pilkington classics had the correct tooling and were willing to apply the E-mark to a single order at a very reasonable per-screen cost (so reasonable that I ordered two to be safe). However, there are a couple of snags; if they don’t have the tooling for your car it’ll be thousands of pounds to commission one (you can check their list here), and (more worryingly) they seem inconsistent in their approach to E-marking classic screens. When I ordered my windscreens from them they were happy to certify and mark it to the ECE standard, however the last time I spoke to them about another car they stated that there is an administration charge and an MOQ to certify screens that have only previously been BS-marked. The things they are now looking to charge their customer for do not seem to be justified/required under the ECE regulation, so unfortunately this simply comes across as a way for them to make more money…their position on charging for E-mark certification does seem to vary greatly depending on who you speak to at Pilkington, so “you’re mileage may vary”. I am currently investigation a potential alternative in mainland Europe, if this comes to anything I will update this post.
Side Windows:
1. Order polycarbonate windows: As polycarbonate is allowable under the IVA, can be obtained for any car (as the manufacturers can use your originals as templates and formers if they don’t already have templates on hand), and is often very affordable, this is the obvious easy answer for side windows. The best company I found was Plastics For Performance as they are sensibly priced, offer many enhancement options, and can apply proper E-marks to their products (noting many of the other UK-based companies were offering E-Mark stickers that are not allowed under the IVA). Things to consider:
• Consider getting your lexan windows “thermoformed” if they are winding windows (they will then operate in the window channels much like the original glass did)
• Consider getting your Lexan “hard-coated” if they are likely to wear (winding windows) or you want them to be a permanent solution (i.e. you don’t think they will ‘fall off’ after the IVA test).
• Insist to P4P that they use engraving for the E-mark if you have winding “hard-coated” windows, P4P have issues with the marking ink properly adhering to the hard-coat surface (ask me how I found out). If you get them to engraved then print the E-Mark it’ll not be at risk of being scratched off at all.
2. Commission new toughened windows: I went with this option, but in hindsight I would probably still recommend option 1 due to cost. To commission the side glass for my car it cost approximately 2.5x what the hard-coated & thermoformed Lexan would have cost; noting that I’ve ended up with 3 full sets of glass due to MOQ’s (that I may be able to sell to recover some of the cost delta), and I’ve got a far superior and more permanent solution (these will never need to eventually “fall off” after the test). If you do go with this option, I would recommend Safety Glass Industries Ltd (01618770011). SGI have established links into several European glass manufacturers, have been able to obtain small batches of bespoke curved glass, and can arrange all the required CAD drawings. They’re very helpful nice people, but you need to recognise that any single order from a car enthusiast is a small order to them and their Supplier; patience is mandatory.
Rear Window:
1. Order a polycarbonate rear window: This is mostly as per option 1 for the side windows; however, to save some money, it’s not as critical to have the panel ‘thermoformed’ or ‘hard-coated’. The lexan rear screen will form itself reasonably well once it’s in the window rubber (thinner Lexan can be specified to assist with this), and there’s not such a high chance of it scratching (assuming you don’t have a rear wiper). It’s also not as essential to insist on engraving for the E-mark, but I’d recommend it as my first rear screen had to be sent back to be re-worked when the markings were slightly rubbed off by the packaging in transit.
2. Commission a new toughened rear window: Unless your rear window has a continuous curve, or you’ve got more money than you know what to do with, go for option 1. Most rear screens are either compound curves (curved in two planes), have a non-continuous curve (curve-flat-curve), or both; to make such a toughened screen would require a bespoke tool. I had an estimate of £2500 just for the tooling to do my firenza rear screen…I went with Lexan/Polycarbonate.
• NOTE: Although it’s rare for them to have retained tooling for most classic rear screens, it’s always worth asking companies such as Pilkintons; you may get lucky.
General Notes:
• If any commonsense or logic was applied by those writing the rules, the BS Mark would still be allowable under the IVA…but it is not…it sucks, but there you are.
• I’ve seen many threads where people ask whether you can simply go through the IVA test with windows missing; Note 6 within Section 45 specifically precludes this as an easy way out. Put simply, if there is evidence that a window should (or more accurately could) be fitted you will probably fail the test based on a window having been “deliberately removed for the purpose of the test”. So, unless you want to weld up the window channels, remove winder mechanisms etc., it’s a nonstarter for most types of car.
• There appears to be some common confusion around what markings are required for toughened glass side windows. On first reading many (including me) think they need to be marked with VII in addition to the E43R. This is not the case; toughened glass side windows do not need to have the glass ‘type’ appended to the E43R marking. It took me some time to understand the rules on this one (including digging into the ECE regulation itself), but for some easy proof, take wander outside and look at the side window of any ‘modern’.
• Another idea that is often mentioned online is whether an E-mark sticker could simply be applied to the glass. Whether applied by the window manufacturer, or faked by the builder, a sticker will not pass the IVA test. All markings must be ‘permanent’.
• There may be potential creative work arounds for the rear and side (not for windows ‘partly or wholly on either side of the driver’s seat’ though) that may not constitute a fail…for example, I have seen some vehicles that have solid metal panels mounted by a window rubber instead of normal back window…but I’ll not cover such shenanigans here.
• When faced with additional build cost, it may be tempting to fake compliance by counterfeiting the required markings (permanently etching a copy of a real E mark onto a blank windscreen for example). I’d strongly advise against doing this; the IVA examiner only has to ask for a receipt from the manufacturer (which they can do) or check the article registration with the manufacturer to uncover the fraudulent attempt. If such an attempt was uncovered during the test I’m not sure what action would be taken by the authority, but I’d not fancy being in that situation.
Disclaimer:
I’ve elected to build my “radically” altered Vauxhall Firenza to comply with the requirements laid out under the IVA process (LINK). I will be taking my build through the test, I will end up with a Q-plate registration, it has added cost to my build, and I’m fine with it. However, I’m also 100% fine with individual choice…if people choose not to observe the IVA for whatever reason, it’s all good.
Whether you think we’re lucky to have the IVA route as an option in the UK, or you simply want the requirements to go away, this post/thread isn’t intended to ignite another debate on the topic. The intent is to highlight one area where IVA compliance can be troublesome, and to offer up some options that may or may not help people overcome it.
Note: I’m not an IVA expert, everyone should read the manual to understand the rules for themselves before committing any time and money to it. Any further additions or clarifications from those that are more knowledgeable than I will be appreciated/welcomed.
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