Headlights and Compliance
The question of headlights and compliance is confusing because apparently the inspectors themselves apparently are unclear about this topic. Therefore it may help to be armed with some of your own information before you go to face the inspector.
DOT Compliance: European nations, Australia, Japan, South Africa, and Canada recognize forward illumination lamp ECE (also called "e-code") compliance as certifiable for road use. (By contrast the US standard is SAE). This is outlined in the Motor Vehicle Safety Act, under the Motor Vehicle Safety Regulations, by which the CMVSS are based. The authority to use E code headlamps is designate under Sec 108.1 sub (1) sub (a) with subsections i thru v defining which bulbs are compliant, with ECE Regulation No. 20 being the subsection of interest relevant to H4 bulbs, the most commonly used for conversions.
Because some nations like Japan, the UK, and Australia have the steering wheel mounted on the right side of the car (RHD, for Right Hand Drive) and other countries have the steering wheel mounted on the left (LHD, for Left Hand Drive) E Code lights are marked for 'directionality' - whether the beam pattern is designed for RHD or LHD. A JDM car with stock headlights, for example, can't be safely driven on a road in a LHD country because the beam pattern would rise toward oncoming traffic rather than to the side for sign illumination. ECE lights are usually marked to indicate whether they're intended for LHD or RHD applications.
This is only a summary, for a more accurate description of this topic from the Daniel Stern website, click here.
Because some devices incorporate signaling functions and a low beam headlamp, both kinds of arrows may be found on a combination device. When in doubt about the meaning of the arrow, check which function marking is nearest, and that's the function to which any particular arrow applies. For instance, if you find an arrow → near an 'A' mark on a front lamp cluster, it refers to the side of the car for which the parking lamp built into that cluster is approved, and not the traffic direction for which the headlamp in the same cluster is intended.
In summation then, any number after the E is acceptable, as long as the beam points the right way. If it has no beam direction marking at all on it, it is automatically a LHD headlight. If it has an arrow pointing to the right (as you look at it), it is RHD and not acceptable, and if it has arrows pointing both ways it is switch able and also acceptable.
As mentioned above, the regulations are province specific. In Alberta, compliance issues are covered in the Traffic Safety Act under Reg 322/2002, "Vehicle Equipment Regulation". Sec 4 sub (1) defines standards applicable under the Act. Of interest here and worthy of making note: sub (a) which give the above mentioned Motor Vehicle Safety Regulations their authority in Alberta. Then 4(3) sub (b) states: " A lamp or replacement lamp on a vehicle complies with this section if it has a mark or label on it that indicates in words or symbols that the appropriate standard has been met." I.E. the ECE markings referred to above. Although this regulation appears to indicate you do not need a high mount stop lamp, the "Inspection Methods and Standards Manual" states that you need this as well as other items (see "reminder" below).
Further resources...
Alberta Compliance :
Robert Ireland , Vehicle Safety Specialist
Alberta Infrastructure and Transportation
Transportation Safety Services Division
Vehicle Safety and Carrier Services Branch
Ph. 780-427-6798, Fax 780-440-8717
Robert.Ireland@gov.ab.ca
(See: Program Notice, Vehicle Inspection Standards Reminder issued to ALberta Inspection facilities)
Errata:
- CMVSS 108 (Canada) requires daytime running lamps on all vehicles made since 1 January 1990, while FMVSS 108 (USA) merely permits DRLs
- CMVSS 108, through an adjunct called CMVSS 108.1, permits European Headlamps while FMVSS 108 prohibits them.
Both standards differ markedly from the ECE ("European") standards used in most other countries worldwide, not only in technical provisions, terminology, and requirements, but in format: Each European standard deals with only one type of device, while the single U.S. and Canadian standards regulate all devices.
What lights do I buy?
Some vehicles that have the same body type sold in North America may have factory headlight modules available from the North American dealers. This is true of the Toyota Land Cruiser. However, they are $900.00 and the eCode lights are about $350.00. So for most, the short answer is E code lights. For a vehicle like the Delica, eCode lights are your only option. Which e-code lights? Lights that come from an area where they drive on the left side of the road. On the lights you are buying,( the following information taken from Daniel Stern Lighting Web site and reproduced here for reader's convenience ) the uppercase "E" in a circle means the device is type approved to an ECE Regulation, while the lowercase "e" in a box indicates the device is type approved to an EEC Directive. It's rare to find one marking without the other, since the requirements are essentially identical. The number after the "E" or "e" signifies the country in which approval was granted. This doesn't necessarily indicate anything about the quality or performance of the device, though some countries' test-and-approval labs have reputations for being much stricter and others have reputations for being quite lax. The number also doesn't indicate where the device was designed or manufactured. Under ECE and EEC regulations, an item of motor vehicle equipment type approved in any ECE or EEC member country is acceptable for use in any other country that permits or requires vehicles and vehicle components conforming to ECE or EEC safety regulations. Many Canadian importers who offer conversion equipment seem to be offering E13 (Luxembourg) or E11 (UK) coded light pods.
(End of quote from Daniel Stern Web site).
Finally, a few observations, thanks to Brian Halliwell of Calgary:
"H4" is an axial hi-low beam pattern as opposed to the North American parallel pattern.
In Canada, Bosch SBQ11 or SBQ7's from Canadian Tire are the equivalent of an H4 European Code headlight. (7's are 7" round headlamps and 11 is 5X7 square pattern). In B.C. where they have Lordco stores you may source Hella where they have a different numbering system, E.G. "6024" for SQB7's. Parts Source in Calgary was another store that had the Hella's which cost about $50.00 more than the Bosch.
HID Lights
If you are contemplating an HID conversion for off-road use (which are illegal for street use, (click here for more info ), using separate bulbs for hi/low h1 h3 beams using HID ballasts and bulbs could be a workable solution to low light output. Low cost HID systems have an unacceptable warm up time for full illumination. As they take 4-5 seconds or more to warm up, it is imperative that they are not switched off during the dipping process (I.E., leave the low beams on continuous). As inspectors may not know that automatic leveling systems are part of the installation, such an installation may not pass inspection.
And finally. Unless you're a teenager, the K value of your HID lights should be around 4300K, not 8,000k which are are so blue that people have a hard time distinguishing between your car and an ambulance or police car. The lower the Kelvin value, the more Lumens of light you will have. Putting an HID lamp in an existing headlight pod achieves the brightness of using HID but the beam pattern is scattered like a halogen bulb because the housing is not meant for such a light source. In many jurisdictions the use of these HID kits are illegal because they are not focused and glare other drivers. The popular trend now therefore, is to take the entire HID technology (HID bulb, ballast, lense and shield) and put them into the halogen housing. It is the lense and shield of the projector that concentrates the beam to the ground and creates a cutoff above a certain height as to not blind other drivers. This is referred to as a HID retrofit ($1,000+) and is a better method because it incorporates the addition of the HID projector which is the proper way to do it, and it is legal if done correctly see: HID Guide to Aftermarket Projector Headlights. In this regard you may want to heed the advice of Brian Halliwell who points out that if you're considering an possibly ill-fated marriage with HID for your car you'd be better off looking at your car's wiring first, then reconsidering that high end tungsten lamp:
"Rewiring to heavy gauge is effective at improving the light output of regular tungsten lamps: actually can be a very effective remedy and highly recommended as many mfg’s have long and involved wiring runs using light gauges of wire to save weight "
Brian points out that he has rewired headlamps with 10 gauge wire right off the alternator using relays works well as long as the units themselves are of quality design.
Recommendation for HID Kit components:
1) Rebased Philips bulbs (4100k is the brightest but also yellow looking. 6000k is white looking. 7300k is a very crystal blue looking)
2) Hella or Philips generation 3 or 4 ballasts
3) Buy or build yourself a wire harness to power the ballast from the battery with the headlight harness used as a constant source switch.
Recommendation for retrofit components:
1) Cars with H4 high and low beam in a single bulb should use the Acura TL bi-Xenon projectors (which mimics having high and low beam in one projector). Otherwise use the S2000 or the TSX projectors.
2) Use D2S 4100k or 4300k bulbs made by Philips.
3) Use Hella or Philips generation 3 or generation 4 ballast.
4) Buy or build yourself a wire harness to power the ballast from the battery with the headlight harness used as a constant source switch.
It may interest the reader to know that Daniel Stern has done an extensive and very detailed comparative engineering and performance analysis of Japanese vs.
SAE vs. ECE automotive lighting standards that clearly demonstrates the functional equivalence of most Japanese-spec lighting devices to applicable Canadian standards (brake lamps, tail lamps, reversing lamps, turn signals front-side-rear, parking lamps, fog lamps...basically everything except headlamps). This analysis has been very effectively used in some Canadian jurisdictions to gain official approval of many automotive lighting devices not bearing SAE or DOT marks.
This analysis is available for purchase to any interested party who is in the process of working with their local authorities regarding the question of compliance standards.
