i'm sure the almight Doc has said in the past that the rules regarding these bits (the washers for sure) only apply to factory fit items.
For some reason retro fit Xenons don't have to have the waskers etc??
Nope, that's tosh. I don't wish for the Doc to cast away his white coat

, but he may need to re-examine this difficult patient

.
It's all to do with Type Approvals, both UK and EU. Any car sold, and subsequently used in the UK has to comply with both Type Approvals - the main legislative framework in the UK is the Construction and Use Regulations (CUR). Basically, certain bits on a car, to comply with the CURs have to have an appropriate "E" approval. These include things like seat belts, tyres, and all vehicle lighting. Both the light assembly, the luminaires (the bulbs, LEDs, HID capsules), and any other item directly relating to the lights (HID ballasts, leveling devices, even the light switch).
There is no exemption to any aftermarket device which replaces the OEM part. If you want to retro-fix HID Xenon headlamps, then every component which required OEM "E" approval, should be replaced with "E" approved parts. There is quite a bit of engineering to introduce two level sensors, the automatic headlamp range ECU, and the headlamp washers, as well as the proper "E" approved headlamp assembly and luminaire. You may be lucky with the headlamp washers, because some "winter pack" options often have them, even on plain halogen lamps.
Any person who uses any motor vehicle on public roads which breaches the Construction and Use Regs does commit an offence under the Road Traffic Act, and can be prosecuted accordingly.
There has been much publicity in some of the trade only press with this specific regard to aftermarket fitment of HIDs, along with the potential penalties. I'm only trying to make people aware of where they stand, law-wise.
