Fraudulent Compliance Markings

LED HeadlightI am thinking about upgrading the sealed beams on a vintage car to LED headlights. The LED headlights I'm considering are marked "DOT SAE" on the front. Does that mean that they are legal on roadways in B.C.? The gentleman that posed this question also supplied a web site URL with more information that promised DOT approval and explained that these lights were used by international Baja racing teams. Sounds good, doesn't it?

I looked carefully at the picture of the light on the web site. Not only did it say DOT and SAE on the lens, it also had the European E marking. The trouble is, these are usually exclusive in my experience. The lenses are either DOT/SAE approved or carry the E mark, but not both.

What was missing is the type designation that goes with the DOT/SAE marking to tell what function the light fulfilled.

At this point I was convinced that the headlight replacement that this person wanted to buy was not a wise purchase. Just to be sure, I drew on the expertise of Dan Stern, a vehicle lighting expert and Editor in Chief of Driving Vision News. Did this headlight meet standards?

His response was No, and it's not a headlamp, it's a headlite-shaped trinket, one of a mountain of them. It's a pathetic knockoff of the legitimate headlamps made by JW Speaker.

This headlamp does not actually bear any safety certification or approval marks. It has fraudulent partial markings specifically designed to falsely assure buyers who cannot reasonably be expected to spot the difference.

More generally: it is very easy to get bogged down in "What about this one? How about this one? I saw this other one, is it OK?  It says DOT, that makes it OK, right?" types of endless loops. Fact is, there are only a very few legitimate brands of LED headlamps to replace standard-size round and rectangular halogen or sealed-beam lamps. With the widest possible inclusion (meaning these are legitimate lamps, not necessarily excellent ones) they are, in no particular order:

  • Truck-Lite
  • JW Speaker
  • Peterson
  • Maxxima
  • HiViz
  • Grote (rebranded Maxxima)
  • GE (rebranded Truck-Lite)
  • Sylvania Zevo (rebranded Peterson)
  • Philips (rebranded Truck-Lite)
  • Harley-Davidson Daymaker (rebranded JW Speaker)

On a closely related note: The "LED bulbs" now flooding the market are not a legitimate, safe, effective, or legal product. No matter whose name is on them or what the vendor claims, these are a fraudulent scam. A halogen lamp -- any halogen lamp -- equipped with one of these will not produce an appropriate, proper, safe, or legal distribution of light.

Same goes for "HID kits" in halogen-bulb headlamps or fog/auxiliary lamps (any kit, any lamp, any vehicle no matter whether it's a car, truck, motorcycle, etc.). The particulars are different for LED vs. HID, but the principles and problems are the same overall.

There is a task force within the Society of Automotive Engineers Lighting Systems Group working to devise a technical specification for LED retrofit bulbs for use in halogen lamps. There are tall technical challenges to making such a retrofit bulb that actually works acceptably, and such retrofit bulbs are still several years away. When they become available, the situation will actually be more complicated than it is today, because then consumers will have to discern between legitimate and fraudulent LED bulbs: "some of them are OK and others aren't".

For now, the situation is comparatively simple: Halogen lamps need to use halogen bulbs or they don't (can't, won't) work effectively, safely, or legally. This is not like trying out different bulbs in the kitchen or living room or garage, where all it has to do is light up in a way you find adequate and pleasing. Headlamps aren't just flood or spot lights; they are precision optical instruments (yes, even a cheap and minimal headlamp counts as a precision optical instrument) that have a complex, difficult job to do in terms of simultaneously putting light where it's needed, keeping it away from where it's harmful, and controlling the amounts of light at numerous locations within the beam to appropriate levels (too much light in certain areas is just as dangerous as not enough). Headlamps cannot just spray out a random blob of light, and that's what they do with anything other than the correct kind of light source.

"Legal" is a bit of a slippery target in Canada, because Canada Motor Vehicle Safety Standards do not adequately regulate the aftermarket. There are stringent standards that apply to headlights and bulbs installed by a vehicle maker as original equipment, but those national standards aren't written so as to allow Canada Border Services Agency to stop the flow of unsafe aftermarket lighting equipment into Canada. However, for several reasons this does *not* make an anything-goes situation; provinces and territories can still enact vehicle equipment requirements, and many of them require vehicles used on public roadways to have lighting equipment that complies with the applicable Canada Motor Vehicle Safety Standards (namely: 108 and/or 108.1). Furthermore, even if one happens to live in a place where the vehicle equipment code is silent on the matter, or is laxly enforced, there can be severe liability consequences to using unsafe lights. After a crash, if a vehicle is found to have lights that don't meet the standard, and that is even potentially a contributing factor in the crash, the owner of the vehicle stands to get absolutely *hosed* in court, and could face ruinous liability costs. So grinning and saying "Well, it's not illegal in my province" or "Well, the cops don't care" is foolhardy.

Nevertheless, even major brands (Philips, Sylvania) have taken advantage of the outdated limitations in the national standards to market what they claim are LED retrofit bulbs for halogen headlamps. It's unfortunate that they're allowed to profiteer this way.

Yes I will chime in to say that I will only buy OE Branded fit bulbs. I tried upgrading to LED “Replacement” lights and was very sadly disappointed. I will only stick with what is supposed to fit and what I can buy from over the shelf.

As I age, I find my night vision behind the wheel increasingly troublesome with oncoming traffic. Perhaps more drivers are failing to dim their headlights for oncoming traffic. Up until now, I have just assumed that it's just my poor old eyes, but your article has me thinking that some of that difficulty comes from those fraudulent headlights.

There are a lot of horrible so called headlights that are retrofitted because no one appears to have any interest in the application. Try driving at night on highway one in the interior and they are down right blinding, let alone people that have no idea about dimming their lights.

On the other hand I have a 2015 GMC 1500 that has the absolute worst headlights on any vehicle I have ever owned. After many complaints to the dealer there response is that they meet Transport Canada’s requirements and that is all they will do. They have since improved them on newer model years but are not retrofittable to the years that are poor.

So if our legislators cannot make GM improve a poor ( as in being dim) headlight how can we expect them to monitor the aftermarket crap that is out there?

Fact - headlights are rubbish. Also see IIHS on the subject. So, no surprise that people are legitimately desperate for something to help, especially in the over fifty age group. Or at least, the people who can't afford a brand new top safety pick plus are desperate.. There have to be at least a few of us in BC not actively engaged in drug dealing, money laundering, real estate flipping, and the like, so something that we don't need a very large bag of twenties to buy does look appealing. Sad, but true.

Eeee, when I were a lad, back in the day, I worked in a vehicle repair shop where we installed and aligned aftermarket Cibie headlights. At the time, they were a revelation to all who went there. Biggest customer, of course, was the RCMP. As you no doubt know.

Then again, there was also a time in the distant past when we had variable speed limits - one for daytime, one for dark. Logical, but plainly unappealing politically.

Difficult waters, these.

You can bolt on whatever Chinese stuff you want it seems.

Some of the aftermarket headlights now put on vehicles should definately be disallowed, especially on tractor trailer units. Too high and blinding and I'm sure a cause of deaths.

Many do not dim their lights. I see too many trucks and cars with one headlight.

The people who operate "the scales" should be required to hand out warning tickets,but that would be extra work.

The RCMP? well that is also a requirement to turn around and then have to get off their butt.

I am 100% in agreement with the mayor of Surrey. We need a provincial police force again and a highway patrol.

You sure don't see all  this laxity in the western states.

In the U.S. the NHTSA has started testing vehicles for headlights which should help in the next few years for U.S. vehicles.

Back in the 50's it stated in the MVA that one could only have two lights when on low beams. I believe that regulation should be brought back in. I find the people that insist on using their fog lamps one of the biggest glare problem. And these fog lamps often get caught on curbs and can be aimed anywhere.

Running rural roads most of the time another problem I see is people not switching beams. I think with so many living in the city today they hit the highway and for the few that do put their high beams on forget to switch back to low when meeting cars.

Canada should remove itself from going with what the Americans do and switch to the European regulations. Most of the mfg. there have started putting in adaptive lightning. They use sensors and eliminate the need to dim headlights as they lower to avoid glare for approaching and vehicles in front of you well at the same time providing high beam lights for objects beside the road. On one VW model they project a pair of lines indicating the width of your vehicle. If you are towing a trailer it can be set to indicate where the trailer is tracking. Very handy when you meet a vehicle towing a trailer and the trailer is actually in your lane. Another common problem with tourist.

Sticking with European regulations back in the 60's I installed a set of Cibies. Not sure if they were really legal or not but never had a problem and as someone else pointed out most of the highway patrol cars were fitted with them.

I have written to BCAA and even our moderator here to do an article on loading up your vehicle and when you hit the road stop at your local service station and get your headlights aligned for the weight in your car. I find many vehicles have lights that are fine when empty but put a heavy trailer or load a couple of skidoos into the back and even low beam is inspecting the tree tops.

I would be interested in how many find the new light bars supplied to emergency vehicles are unnecessary bright? Fine in daylight but once it is dark the glare is terrible. To me it is the complete opposite to what you would want as it reduces vision of what is on the road. Have also seen flag people standing in front of their vehicle with high beams on, bright emergency lights and standing in the centre of the road. Fine for people travelling in the lane they are stopping traffic as they are illuminated by the headlights but not so for traffic approaching them.

Age definitely plays a part for some of us but I even hear teenagers complaining about the lights on some cars.

With the technology we have today every weight scale and police vehicle should be equipped so that as the trucks pull in to the scale and vehicles met on the road their lights are checked. If not properly aimed pull them off the road till they are. And it wouldn't hurt if we could quit focusing on speed, seatbelts, cell phones and do a check of lights when the police pull a vehicle over. I've known them to ticket for not having a seatbelt when the Daytime running lights are not operating. Here is a safety item that is never enforced. And then we wonder why we have accidents.