Just received this on email from the DVSA ( used to be VOSA ) re -advice to MOT testers.

Question- Do LED headlamps require washers / self levellers?

Headlamp washing and levelling systems are a legal requirement and required if the LED headlamp or high intensity discharge lamp has a luminous intensity exceeding 2,000 lumens.

If the luminous intensity isn’t marked on the lamp, a tester won’t be able to tell if these systems are needed. In this case, the headlamps will be treated as ordinary lamps and the vehicle can be passed as they don’t need washers or levelling devices fitted.

The headlamp washers and levelling systems can only be rejected if they’re fitted and are inoperative or obviously defective. If they’re missing and you think they should be fitted, then pass and advise.

Reference - https://mattersoftesting.blog.gov.uk/customer-service-centre-commonly-asked-questions/