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I don't see any reason why they wouldn't be legal although it wouldn't have been where I chose to place them personally. :)
 

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You sure? I've seen a few cars with factory standard DRL's down at fog light level. Dacia Duster being the first to spring to mind.
I think its to do with how they are mounted. I can remember where I saw it
 

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Legally they need to be over 250mm of the ground so your ok there
Now they do have to be fitted withing a certain diamiter of the outside edge off the car, I honestly couldn't say as I'm not 100%
Also the DRLs need to dim to half brightness when the headlights/sidelights are on, to prevent dazzling.
Hope this helps.
 
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