Let There Be (Compliant) Lights

The glow of headlamps can stretch across a darkened highway in a rainbow of colours, from the yellow tinge of incandescent bulbs to the vibrant blue-white associated with High Intensity Discharge (HID) designs. Tail lamp assemblies will offer colours of their own.

And many of them are blatantly illegal.

Many of the lighting options that are easily found in the aftermarket will not comply with rules that can be enforced by provinces and local police, or the Canadian Motor Vehicle Safety Standards that are applied to vehicle manufacturers.

“Much of the aftermarket is style-driven, and the goal isn’t always safety and compliance,” suggests Daniel Stern, a Toronto-based member of the U.S. National Academy of Science Trans-portation Research Board Visibility Committee. “The best advice I can give is for jobbers to stick to a reputable brand line for their bulbs [and lighting assemblies] because all of the major makers have enough of a high profile.

“They’re not stupid. They’re not going to make an illegal product.”

Then again, the wide availability of non-compliant products could lead jobbers to believe that it’s perfectly acceptable to stock the other options on their shelves.

First, let’s consider the legal options. Canadian regulators will accept headlamps with a “DOT” marking, or its European counterpart in the form of an “E” and the number associated with the country of origin. And there’s certainly room for aftermarket products to improve upon Original Equipment designs. A recent legal interpretation by the U.S. National Highway Traffic Safety Administration allows manufacturers to design all sorts of replacement bulbs as long as they meet the same “photometry” and function of those they replace. Transport Canada will even give an accepting nod to emerging technology such as Adaptive Front-lighting Systems, which adjust headlamp intensity and direction depending on factors such as speed and vehicle angle.

But challenges begin to emerge when consumers want to “update” the lights that came with their vehicle.

Questionable kits

Ontario, for example, has become a major market for HID kits designed to let motorists switch to the blue glow of High Intensity Discharge, or xenon, headlights which rely on a high-voltage arc in a xenon gas-filled bulb to produce a bright light, Stern says.

But these kits seldom include the required optics and headlamp assemblies that need to be matched to the bulbs, making them illegal.

“In no case is it legal or safe to equip a headlamp with a bulb other than that for which it was originally designed,” he says. “Under no circumstances, in no case, is it legal to have an HID kit that simply replaces the bulbs.”

“I’ve seen products that are without question outside specs. They are such a brilliant blue, it’s impossible they’re meeting specifications,” adds Michael Scheiven, Philips Automotive Lighting’s director of the aftermarket channel for North America. He points the finger for some of the image problems that HID lighting has suffered, namely that the glare is blinding oncoming drivers, squarely at non-compliant kits and bulbs. “It’s my opinion that OE-quality HID does not create the glare concern as much as the non-compliant upgrade lighting.” (Studies seem to bear this out.)

The choice is more than a matter of safety. Cheap knock-offs of HID technology could lead to power spikes that can damage vehicle electronics, adds Marcin Gorzkowski of Transport Canada’s Motor Vehicle Safety Enforcement Branch.

Kits that offer LEDs as a replacement for filament-based bulbs are also a problem. Filament bulbs spill their light as a sphere, so the associated parabolic reflector and pillow optics in the lens will not be able to spread the focused beam of an LED.

“That’s why these so-called ‘LED retrofits’ consisting of a one-inch diameter matrix of LEDs on a bayonet or wedge base are unsafe. There’s no way you can get enough light through a wide enough angle (horizontally and vertically) to create a safe and legally-compliant lamp,” Stern says. “The main problem with most DIY LED ‘retrofits’ is that it’s really tough to get enough light through a wide enough angle.”

Coated bulbs

Some coatings used to alter the nature of a bulb’s light–perhaps to give it that popular blue tinge–can also be a problem.

“Any time you filter something, you’re taking part of it away,” Stern says.

Headlamp specifications require a certain amount of light, within a tolerance of 10% to 15%. Unfortunately, some suppliers have taken what was originally meant to be a production tolerance, and used it as an opportunity to add the coating.

The legal amount of light then comes from upping the wattage of the bulb, and that shortens its lifespan.

The problems don’t always relate to a headlamp’s intensity, either. Some tuners have been shopping for Japanese Domestic Market (JDM) headlamps to put on their import vehicles, yet these designs are aimed for driving on the left side of the road.

Manufacturers are clearly banned from installing these designs under CMVSS 108.1, the federal regulation covering lighting.

Counterfeit products

It’s not the only problem with a decidedly Asian influence.

The first indication that you’re ordering a counterfeit bulb or lamp will usually be found on the invoice. Asian-sourced knock-offs–usually shipped under the cover of darkness (like the inside of a shipping container)–tend to cost about two-thirds as much as their legitimate counterparts.

“If you can bring in a 9004 bulb, at say 25% to 30% less than a Philips or Sylvania bulb as an example, you’ve got to start wondering [if it’s compliant],” adds Scheiven. “I don’t think people think we’re that dumb to demand that sort of premium.”

The difference in price often comes down to sacrifices in quality.

“Most of [our core products] are made using automated equipment, so the difference in labour is minimal. The difference is the materials,” explains Brad Van Riper, vice-president of research and development for TruckLite. A standard four-inch stop, turn and tail lamp for a trailer, for example, will be shielded by a polycarbonate plastic housing. Cheaper plastics will be prone to cracking and other weather-related damage.

The recent surge in counterfeit lamp designs came with the emergence of LEDs in the automotive market, he suggests. Asian manufacturers were already familiar with the electronic foundation of LEDs before they were added to vehicles. They simply applied the knowledge to a different industry.

“There are much lower-cost diodes out there that can be used that provide a lit appearance, but they do not meet photometric minimums.”

Cut corners often relate to how well the lamps attach to vehicle wiring. Cheaper assemblies often lack sealing rings or secondary locking devices for wiring harnesses, adds TruckLite’s Greg Jordan. These are the shortcuts that can allow road salt and calcium chloride to seep inside. “Corrosion is the foremost killer of everything.”

Perhaps the most disturbing trends have involved efforts to fool wholesalers into believing they’re selling legitimate products. Blister packs, for example, have been marked to suggest that the lights inside are legal, but the lights themselves bear no markings at all.

“We’re also seeing, from time to time, our boxes with TruckLite logos on them, with the top layer [consisting of genuine] TruckLite, and the layers below consisting of a mixture of those built at two-thirds the cost,” Van Riper says, and emphasizes the need to buy from reputable sources, and randomly inspect shipments.

Coloured tail lights

Compliance problems aren’t limited to headlamps, and jobbers should be wary of stocking any turn signals available in something other than colourless-clear or amber.

“We are seeing some legal turn signal bulbs with a blue chrome appearance when they’re off, but they light up in an amber colour,” Stern says. “[But] you see red, green, pink, blue and purple ones. None of that stuff is legal.”

“The tail lamp market is atrocious. You can see those lamps of different colours or no colour. I don’t know why people are putting them on the vehicle, but they’re a plague in some areas. They definitely block the proper light coming out of the original equipment,” Gorzkowski agrees.

Enforcement

Granted, enforcement efforts have been sporadic, despite the extent of the problem. Canadian Motor Vehicle Safety Standard 108 is largely a mirror image of the similarly numbered Federal Motor Vehicle Safety Standard that’s enforced in the U.S., but the aftermarket on our side of the border is a provincial jurisdiction, creating a significant barrier to coordinated crackdowns.

“Many provincial lighting codes are badly out of date and sorely inadequate,” Stern adds. “Not through any active neglect, but 20 years ago who was messing with their lighting?”

Legitimate manufacturers face their own challenges in trying to comply with the rules. “It is very difficult for all lighting equipment suppliers to properly interpret and develop clear and consistent design compliance guidelines for their products,” offered Hella North America vice-president for lighting technology Jason Bolin, during a Senate subcommittee meeting in 2004.

The situation was so difficult that the regulation was recently redrafted to make interpretation easier. The regulation was changed, but the mishmash of amendments over the years was smoothed out.

Ultimately, Hella marketing manager John Remakis says the entire issue leads to an important warning for jobbers: if you’re thinking about stocking questionable products, think again.

“Consumers in many cases are better-informed than they’ve ever been,” he says. “If anything falls short, the reputation of the jobber falls short.”