Surely you cannot have a 220Volt GU10 Lamp in one of those silly holder things fitted into a 12volt down light. Nearly every domestic(which I try and avoid) Test and inspect for the COC I find 220Volt GU10's in 12Volt fittings and usually the connection to the supply cable isn't enclosed, just a connector block. I'm bored of dealing with customers who do the "well its worked fine like that for ages" and get annoyed when I don't sign the COC because of this. The fitting says 12V and is not earthed therefore not, to my way of thinking, compliant, Right?
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