Imitation, frequently cited as the sincerest form of flattery, often is frustrating to say the least. But now there’s a new kind of imitation posing a real threat to traffic safety and threatening to poison the market for emergent new vehicle lighting technology. “LED conversion kits” for halogen headlamps are newly and aggressively being marketed. The tactics are essentially just the same as those used to sell “HID kits”, and so are the problems; the only difference is the kit containing “LED bulbs” and drivers instead of HID bulbs and ballasts.
Kits are available under a variety of brand names—some of which, perhaps used without authorisation, are instantly recognisable to anyone in the lighting community—and to fit in place of any type of halogen headlight bulb. The “LED bulbs” themselves generally consist of a metal post with two or more disc-shaped LED emitters facing upward and downward. Some of the “LED bulbs” have (nominal) heat sinks and cooling fans on the back, and most have external drivers and connecting cables.
Of course, as with “HID kits” in halogen headlamps, there is no possibility for a halogen headlamp to produce even remotely acceptable or compliant performance with an “LED bulb” of this nature. The problems, both technical and practical, are at the conceptual level and not confined to any particular design or embodiment. On the practical side, these “LED bulbs”, when installed in a headlamp, spoil the headlamp’s compliance with whatever regulation applies, whether it be FMVSS 108, CMVSS 108, UN Regulation 112, or another rule. By taking the headlamps out of compliance, such an installation also renders the vehicle itself noncompliant with applicable provisions of MVSS 108 or UN Regulation 48 (for example).
But at least in North America, there’s a loophole: the Federal standard applies only to regulated parties, i.e., manufacturers, importers, dealers, and so on, but not to vehicle owners. Likewise, in many countries applying UN Regulations, vehicle owners’ modifications to their own vehicles are regulated not as stringently as automakers’ original build methods.