Office of Vehicle Safety Compliance
National Highway Traffic Safety Administration
Washington, DC 20590
Please don't overwhelm him with email. He and others actively search for the sources of HID kits: importers and manufacturers. Distributors and retailers must stop selling, but the importers and manufacturers or their US agents, if overseas, are responsible for recall and remedy.
To date, NHTSA has investigated 24 HID conversion kit suppliers; all investigations have resulted in recalls or termination of sales.
J. Liu LLC
SPW Industries, Inc.
McCulloch Motors, Inc.
Outback Products, Inc.
GR Motorsports, Inc.
American Products Company (No. 25, not reported because they recalled on their own)
Perhaps you could pass on your thoughts about the fitting of discharge headlamps systems into halogen designed cars. In particular
1) Lack of adjustment
2) An epidemic of theft for such systems. Breakers are often sited as the source but many road accidents happen to the front of the vehicle so its amazing how many headlamp systems survive!
3) Glare caused by DIY systems and no optical knowledge
4) Lack of correct wiring and the risk of fires
5) Inappropriate materials used to 'Get it to fit'
6) The legal aspect of carrying out such a conversion
I have been wondering about that too. For the last couple of years, the authorothies in canada have been busy with bill 218 (I think that's the right #), which basically cracks down on usage of all types of aftermarked parts on vehicles (even stickers...)
What they really need to do in Canada is enforce very harsh penaltys for ANYONE selling HID "kits" for halogen housings, AS WELL AS train SMART COPS (oxy moron, I know!).
If the police, the ones that are supposed to enforce the rules once people have installed them, would actually do their jobs right and do some research on the topic, then they'd know who to pull off the road and give fines to.
I've been pulled over for having those stupid little LED washer nozzle things, but they don't do anything for blinding HID plug-in kits.
Let's just hope that bill Herman mentioned doesn't go through because what he thinks it's about, it sounds way too over-generalized and in the wrong direction.
No, just preserving public safety as desired by most citizens. If that were not true, then their representatives in Congress would change the rules under which we operate, reduce our funding, or ask us to do something else. In fact, the Congressional Automotive Caucus has asked us to crack down on noncomplying imported lighting, and it appears that it will* give us two more employees to do that. If that is not what you want, you had your chance yesterday to change that.
*Congress gave us two full time employee slots and $100K for testing.
This message has been edited by Mr108 on Mar 11, 2005 7:01 AM This message has been edited by Mr108 on Nov 3, 2004 7:00 AM
Yes, Transport Canada does not have any authority to address replacement or aftermarket automotive parts. This responsibility belongs with the provinces. You should contact your own province's motor vehicle office. Help them with identifying illegal components.
This message has been edited by Mr108 on Nov 2, 2004 7:13 AM This message has been edited by Mr108 on Nov 1, 2004 7:03 AM
ProjectorZô are the latest innovation in BMW Z3 and Z3 Coupe lighting. Employing Hella D.O.T. legal H9 components, this system will allow you to upgrade your existing Z3 lighting to the ultimate in European lighting technology. The best part? It is D.O.T. legal and ready to legally upgrade to HID technology.
Re: Is HID upgrading in a halogen H9 housing legal?
November 19 2004, 7:43 PM
That ad is the usual mixture of truth, half-truths, misleading statements, and outright B.S. that these HID "kit" purveyors are noted for. Hella 90mm lights with H9 bulbs are street-legal, there are Hella 90mm HID lights that are street-legal, but nowhere is it written that you can take a 90mm housing that is certified street-legal, refit it with a D2S HID capsule, and have it be street-legal. There are differences in the reflectors of the halogen & HID reflectors that distribute the light differently for the different light source types. See this thread for a discussion of those differences: http://www.network54.com/Forum/thread?forumid=216460&messageid=1098305391&lp=1098498875>
Additionally, in order to fit a D2S capsule into an H9 housing and hold it securely in said housing, it takes some fabrication work; this action in itself will make the H9 housing non-compliant in the eyes of the Federal DOT. Having said all that, I will also say that I'm not a "headlight cop": so if you feel lucky, go for it!
This message has been edited by ekooke on Nov 19, 2004 11:21 PM
I own a 94 caravan and I live in Ontario Canada. I was looking into modifying my headlights, thought HID kit would be cool but your rihgt about glare, I definitely don't want someone running into me or anyone else because of glare from headlights. Besides they way to much money for me. I just installed a set of GE nighthawks, they work very well, and no glare.
You are lucky that you don't own a '96 model. Those are worse than the '95. I've had an '88, '92, '96 and an '02. Ranked in order of performance based on my myopic judgement, highest to lowest: '02, '88, '92, and '96. The high-visibility bulbs from major manufacturers do help.
Re: Is HID upgrading in a halogen H9 housing legal?
November 24 2004, 7:41 AM
Ed is correct. That is not legal. Just because you may find a headlamp with bulb markings on it that for example say H9 D2S, that does not mean that the headlamp will work correctly, or be legal with either. The lens may have dual markings, but you need to change the reflector and other interior parts the way that the lamp manufacturers do, in order for it to comply. As an aside, you may also find that such lamps have dual certification markings, both DOT and ECE. That also does not mean that they are legal in both places. Again, it depends on what is inside. The real miscue here is that the lamp manufacturer is saving money by making a single lens molding and using it on all its products for that vehicle, whether a DOT, ECE or Japanese market. P.S., lamp manufacturers that do so and sell them in the U.S. are doing it in violation of FMVSS No. 108. See: http://www.nhtsa.dot.gov/cars/rules/interps/files/19023.ztv.html and http://www.nhtsa.dot.gov/cars/rules/interps/files/22310.ztv.html .
If a lamp is made for an H9, then it is illegal to convert it to HID. Too many people, seeing a headlamp marked with two different bulb type designations, or two different versions of the same lamp design (one with halogen and the other with HID) incorrectly jump to the conclusion the the halogen version can become the HID version by simply inserting an HID source. How far from the true that is.
The optical designs are often markedly different, the heat loading design is different, the bulb holder in the back of the reflector is different. The only reason that some headlamps have dual or triple markings of bulb types on the lens is that the lens is without optical design and can fit the housing incorporating any of the various optical design and bulbs. It saves money by molding only one lens with multiple markings instead of multiple lenses each with a different marking.
Unfortunately, you are duped into thinking that the optical designs are the same and you can play musical chairs with the bulbs. Unfortunately, you are not playing musical chairs, you are playing Russial roulette with your life, and that of your loved ones and other drivers.
Here in California we have rediculous smog laws that are billed as "trying to keep pollutants out of the air we breathe", the truth is that the good liberals here found that they could make a fortune "selling" the air we breathe in the form of "smog credits"...every car taken off the road because it fails to pass smog checks is worth a certain amount of "smog credits" (a car is determined to produce a certain amount of smog during its useful life) that a refinery, for example, can purchase from the state to allow them to pollute that same amount.
The point here is that a lack of common sense - and a blind bureaucratic enforcement - does nothing to enforce the intent of the law and make people safer. In the smog case, you will fail to pass if your car is missing (or a component fails) a smog component, even if it does not exceed smog emission limits.
For lighting, it does not matter if the headlight module - in this example - an HID projector - is approved for the US market but installed on a different vehicle that it was originally installed. Assuming that the module is intelligently installed and properly aimed, it does not matter to the blind bureaucrat who just "does what the rule book says" regardless of god given commen sense.
The main problem is that it is not properly (realistically) advertised that public comment is requested before legislators commit. We only hear about a new ban after the fact, unless some super-sharp (non-bureacrat) individual stumbles upon the pending legislation in time for us to act.
"...it does not matter to the blind bureaucrat who just "does what the rule book says" regardless of god given commen sense."
The book was written in 1985 with lots of advertised public comment. It always said that the replacement light source must comply with the federal specifications established for the OEM light source. It made sense then and it still does. Thanks for appreciating my writings.
The fact that some think that the law is wrong or doesn't apply to them occurs every day. Maybe we should just trust everyone to protect the public good, but that has not yet been successful in real life.
I am new to this technology but I have read FMVSS 108 several times and feel I have a good grasp on what is legal and what isn't. I am going through a process currently to offer an upgraded halogen/HID headlight package and looking at proper spec 108 certification.
What seems to be happening in my eyes is the growth of lighting technology and the challenge for the regulating body to keep up with it from a proactive point of view. Whether it's realistic or not, managing a path for better "legal" lighting for automobiles whether originally equipped so or not would be terrific. I think you would find a lot less law breakers and bad lighting pojects on the road. This should be done more as a proactive effort than a reactive effort. Websites and forums that support this "hobby" should be supporting 108 and in concert with NHTSA from an educational point of view.
Education is the first place to start in my book and for the average joe they aren't going to sit down and read 108. This is where the online forums and manufactuerers can step in.
I have owned many cars that are 5-30 years old and while they do (or did) meet spec, their lighting system is terrible. With the increased population and speed of cars, increased lighting is a safety issue for these older models. I do believe we should have a right to improve the performance of these systems to make us and the other motorists safer. BUT, it should be done safely and legally.
The more people that buy HID-kits and retros and install them improperly and illegally into the cars will perpetuate the illegal crackdown and soon we won't have the option to do much. I would vehemently oppose that. There is no reason why we can't add systems orparts to our cars that: providing they met legal requirements and added additional performance and safety.
Off my soapbox now.
This message has been edited by Miket502 on Dec 26, 2004 2:08 PM
I challenge you to find a way to do it. Testing for compliance will cost upwards of $10,000 at an independent laboratory. NHTSA does not have its own lab and it contracts with such labs when it does compliance surveillance. There is no possibility that NHTSA would ever take on the job of approving of a person's own design. The authority given by Congress states clearly that the responsible parties for regulated motor vehicle items must self-certify.
If it were true that the aftermarket wanted only to build higher performance, complying headlamps, life would be simple. The truth is that only part of the aftermarket wants to do that. A large part only wants to supply different styling for headlamps and signal lamps. In this case, many of them have been shown not to comply at all, let alone achieve "higher performance." Many lamps are imported by people who have no idea that there is even a NHTSA that regulates them and their behavior.
For headlamp lense that have markings molded into the lense, I agree. But the hella 90ís are inkjet marked. It is extremely easy to change it for d2s and h9 printing. All it takes is the layout file to change. Much like an label printer used in manufacturing. All it takes is a software template and a database to feed it. Why would hella in this situation print 2 identification markings h9/d2s on the front lense then? They are not molded in, just inkjet printed.
we have laser etching machine at work as well. and laser etching will leave an engraving on the surface. you can easily tell the difference between ink and laser by the texture of the print itself. the hella's marking is definitely ink printed.