The Lighting Committee of the U.S. Society of Automotive Engineers met on December 3-4 in Troy, Michigan.
One key topic of the talks was the question of whether and how to upgrade compliance provisions in the SAE standards that eventually contribute to U.S. lighting regulations. Presently, SAE standards and U.S. regulations require that lighting devices be “designed to conform” to the stipulated design and performance provisions, but there is no formal definition of what means “design to conform”.
The lack of such a definition has, for the 40 years during which auto lighting has been regulated in America, informally served to provide the room for interpretation and production tolerance which is formally provided under ECE regulations by the COP provisions.
However, with inexperienced companies from low-cost countries joining the worldwide market for automotive lighting devices, this informal agreement to build only more-or-less compliant devices will no longer suffice. There is philosophical resistance to the notion of defining “design to conform” or enacting guidelines for compliance; longtime SAE lighting experts feel the previous arrangement should continue unchanged. However, unenforceable measures such as voluntary guidelines and undefined design requirements can only worsen the counterproductive situation in which established companies who don’t need the guidelines will generally follow them, while inexperienced, low-cost companies will take the view that any provision not defined or enforced is strictly optional.
Discussion on the matter is ongoing, as are proposals to mark each and every lighting device with applicable SAE function codes. Presently, only headlamps are required to be marked.