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Old 10-22-2003, 10:56 PM   #1
Jon [in CT]
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Default Recent DOT Interpretation Letters About HID Conversion Kits

From http://www.nhtsa.dot.gov/cars/rules/...s/kim.ztv.html:
Quote:
Mr. Song M. Kim
C.M.O./Fanteks, Inc.
580 Sylvan Ave., Suite 1A
Englewood Cliffs, NJ 07632

Dear Mr. Kim:

This is in reply to your letter of August 18, 2003, regarding High Intensity Discharge (HID) conversion kits. You informed us that you have been selling such kits to local distributors and dealer shops.

Your first question is whether the use of aftermarket HID conversion kits is "going to be illegal," and, if so, the reason for it. I enclose a copy of our letter of November 18, 2002, to Jeff Deetz, who had supplied an HID conversion kit for our examination. We informed Mr. Deetz that his kit was "not a design that conforms to the Standard [No. 108] and could not be certified as conforming with [Federal Motor Vehicle Safety Standard] (FMVSS) No. 108, nor imported into or sold in the United States."

HID conversion kits are illegal if any item in the kit does not comply with Federal requirements for vehicle lighting equipment. Please read the letter carefully and apply our analysis to the components of the kits you are selling. If one or more of these components does not comply with FMVSS No. 108, then you should cease the sale and distribution of this equipment. Your failure to do so could make your company liable for civil penalties for violations of 49 U.S.C. 30112(a). If your company manufactured or imported noncompliant HID conversion kits for resale, your company is required to notify this agency, dealers, purchasers, and owners of the kits and to remedy the noncompliance in accordance with 49 U.S.C. 30118-30120 and 49 CFR Parts 573 and 577. I should advise you that we know of no HID conversion kit that can be certified by its manufacturer as complying with FMVSS No. 108.

You expressed your understanding that "D.O.T. is an approvable organization," and asked "if we would like to get your approval for HID conversion system, what will be the necessary procedures?" We have no authority to approve or disapprove motor vehicle equipment. We have authority, however, to order the recall of noncompliant motor vehicles and motor vehicle equipment. The symbol "DOT" on an item of equipment is sometimes misconstrued as approval by the Department of Transportation. In fact, the symbol is the manufacturer’s certification that the item complies with all applicable FMVSS, as required by 49 USC 30115.

If you have any further questions, you may call Mr. J. Edward Glancy of this office at (202) 366-5263.

Sincerely,

Jacqueline Glassman
Chief Counsel

Enclosure
ref:108
d.9/26/03
From http://www.nhtsa.dot.gov/cars/rules/...deetz.ztv.html:
Quote:
Mr. Jeff Deetz
Sales Manager
Santeca Electronics, Inc.
7215 East 21st Street
Suite D
Indianapolis, IN 46219




Dear Mr. Deetz:

This is in reply to your letter of July 30, 2002, to John Womack of this office with respect to a High Intensity Discharge (HID) light source conversion kit that you wish to sell for replaceable bulb headlamps in the United States. On August 15, Taylor Vinson of this office e-mailed you to request a sample of the kit so that we might be better able to advise you. The kit arrived on September 12.

Your specific request was "for guidance in how to begin the process of obtaining D.O.T. approval" for your kit. We have no authority either to approve or disapprove motor vehicles or items of motor vehicle equipment. We do advise correspondents of the relationship of their products to applicable Federal motor vehicle safety standards (FMVSS) and other regulations that we administer. If a manufacturer determines that its product is covered by one or more of the FMVSS, and that its product complies with all applicable FMVSS, it must certify compliance of the product when the product is offered for sale. The symbol "DOT" on replacement lighting equipment is often mistaken for "DOT approval" of the equipment but, in fact, it is the manufacturer’s own certification of compliance.

Because your HID conversion kit is intended to replace certain original headlighting equipment, the kit is subject to paragraph S5.8, Replacement Equipment, of FMVSS No. 108 Lamps, Reflective Devices and Associated Equipment, 49 CFR 571.108. Paragraph S5.8 requires that any motor vehicle replacement replaceable light source that is offered for sale in the United States comply with the requirements of FMVSS No. 108. The Federal specifications for replaceable light sources used in original equipment motor vehicle headlighting systems are located in 49 CFR Part 564, Replaceable Light Source Information. The purpose for storing the specifications in Part 564 is two fold: (1) to ensure the availability to replacement light source manufacturers of the specifications of original equipment light sources such that replacement light sources are interchangeable with original equipment light sources and provide equivalent performance, and (2) that redesigned or newly developed light sources are designated as distinct, different, and noninterchangeable with previously existing light sources.

Paragraph S7.7, Replaceable light sources, of FMVSS No. 108, requires in part that each replaceable light source be designed to conform to the dimensions and electrical specifications furnished with respect to it pursuant to Part 564. Thus, in order to use a replaceable light source in a replaceable bulb headlamp, a manufacturer must first have submitted certain information with respect to it (and its ballast if required) in Part 564, or it may use a light source (and ballast if required) if its specifications are already filed in Part 564.

The kit that you furnished us appears to be designed to replace an H1 replaceable light source, and consists of two parts marketed under the name "Thunder Beam." The first part is labeled "HID Bulb Set" and contains two replaceable light sources, identified on the packaging as "WB-H1." The second part is labeled "HID Driver Unit TD-5000," and contains a ballast, an ignitor, a relay, and adapters to convert the motor vehicle’s wiring harness to be compatible with the HID conversion kit.

Based on a review of the H1 light source specification filed in the Part 564 docket (#3397), it is apparent that the Thunder Beam HID Conversion kit is a significant redesign of the H1 light source. At the most basic level, an H1 light source incorporates an incandescent filament in which light is produced by a metallic wire coil heated to incandescence by an electrical current, whereas the HID conversion kit’s light source incorporates a discharge arc to produce the light and requires a ballast for operation. Thus, in order to comply with paragraph S7.7 of FMVSS No. 108, the Thunder Beam light source must comply with, inter alia, the dimensional specifications for the metallic wire coil filament size and location, the electrical connector size and location, and the ballast would need to be a design currently on file for use with an H1 light source. Complying with the dimensional aspects of the H1 light source appears to be an impossibility considering that the wire coil filament and the electrical connector are not a part of your design. Furthermore, there are no ballast designs on file for use with an H1 light source. Thus, your company’s HID conversion kit is not a design that conforms to the Standard and could not be certified as complying with FMVSS No. 108, nor imported into or sold in the United States.

This interpretation would apply to any HID replaceable light source whose base was modified or manufactured to be interchangeable with any regulated headlamp replaceable light source that incorporates an incandescent filament design.

If you have any questions regarding how a manufacturer may submit information to Part 564, you may contact Michael Cole of our Office of Rulemaking (202-366-5276). For legal questions, you may phone Taylor Vinson of this Office (202-366-5263).

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:108
d.11/18/02
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Old 10-22-2003, 11:03 PM   #2
Mulder
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Very interesting.
Short version of the long-winded NHTSA letter-
"HID retrofit kits that replace filament type bulbs with HID bulbs do not comply with Federal standards and are therefore illegal".
No big surprise here.
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Old 10-23-2003, 12:31 AM   #3
Zola
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Exactly. Not only "are", but "have been, are, and will continue to be" illegal. I was really surprised by all the ruckus surrounding this issue recently, because the federal paper trail really isn't that hard to follow. But I guess sensationalism (e.g., "d00d, HID kits just got banned!!") is just quicker and easier than fact-checking.

Last edited by Zola; 10-23-2003 at 12:36 AM.
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Old 10-23-2003, 06:50 AM   #4
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Right, basically all that happened is that NHTSA decided to seriously enforce the existing regulations.
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Old 10-23-2003, 08:13 AM   #5
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Quote:
Originally posted by mulder
Right, basically all that happened is that NHTSA decided to seriously enforce the existing regulations.
Because so many people were violating existing regulations, they decided to add a regulation that tackles the problem on the supply side.

Anyone "upgrading" their headlights should read this stuff and accept what they are getting into.
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Old 10-23-2003, 07:04 PM   #6
kwycstix
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Check me here if I am wrong:

the Bi-Xenon headlamps are a HID design correct? If so, then I can order a Mercedes C230 with standard halagon, or I can select a lighting package with Bi-Xenon headlamps. In this case I just changed from a filament light to a HID light. How is it different if a manufacturer can do this, but us owners cant?
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Old 10-23-2003, 10:02 PM   #7
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Because the OEM lights installed by the manufacturer are designed to meet the federal standards and properly accomodate the HIDs, they won't be identical to the halogen versions.
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Old 10-24-2003, 07:49 AM   #8
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To further clarify what mulder said, original factory HID and halogen systems differ in more than just the bulbs. The following are also different:
1) reflector design. The beam pattern is also drastically different as required by DOT.
2) HID have some sort of automatic or manual levelling provision.


So no, Mercedes does not simply substitute an HID bulbs where a halogen bulbs used to be.
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Old 10-30-2003, 04:12 PM   #9
twistedsymphony
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right....

but say I bought a set of Audi A6 Bi-Xenon headlights with projecters and HIDs...

can I take the projector/HID units out and retro fit them into my headlamps and make that legal?

the projector units and HID units were FMVSS certified for the audi does that certification carry over if I move the entire unit over to my WRX?

in other words is this: [www.hidtech.com] leagal?
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Old 10-31-2003, 04:12 PM   #10
noblebc
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What they are saying is if you have a halogen bulb in your car you need to change it with a halogen bulb. If you want HID you need to have a kit that has both the HID system and a new reflector designed to go with that bulb. If you don't have the complete kit it is not legal. Simple as that.
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Old 11-02-2003, 05:09 PM   #11
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to be even more simple and blatant..

HIDs, aftermarket or factory with proper housing = legal
Ghetto hid wannabe lights stuck into stock halogen housing = NOT legal

If you want HID look and don't have money to actually do something right, get silverstars


what i don't understand is reactions like this [mccullochhid.com]

Last edited by BOFslime; 11-02-2003 at 05:15 PM.
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Old 11-03-2003, 07:38 AM   #12
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so it has to be factory

to protect our nations cars from having equipment that doesnt function as the DOT wants... because we can't figure out what is satisfactory lighting on our own...

i'm sure it all boils down to money. as in, we have to pay factory prices for everything since all aftermarket (practically everything) is illegal for road use.
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Old 11-18-2003, 10:21 PM   #13
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what about the 04 sti lights? would that be legal if put in a wrx?
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Old 11-19-2003, 05:07 AM   #14
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DOT are a bunch of whining bitches...if this were Japan we would all be driving around w/ lightweight bumper beams, more power, HID, and No Smog testing either!!!
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Old 11-19-2003, 05:40 AM   #15
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And you would have to pass an incredibly strict inspection every two years that would verify that all the parts on your car are in *new* condition. They can't put used parts on cars in Japan, everything has to be new. If your calipers have rust on them, sorry, time to buy new ones for the inspection.
That's why Japan exports so many *used* cars: they are in fantastic condition, but people get tired of spending the big bucks to keep them that way.
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