By Paul-Henri Matha
A lot of people have been asking me if a lighted-wheel design is legally possible. That’s not easy to answer, because I am no longer part of a carmaker, nor do I work at a test house for component or vehicle approval. But here are my personal thoughts on the matter:
In China, this is clearly acceptable according to GB4785-2019, in parking condition, according to ¶ 4.31
In China, this is clearly acceptable when the vehicle is parked, according to GB 4785 2019 ¶ 4.31, which says lighting and signalling devices not defined by the standard may be activated if the vehicle is stationary, subject to conditions—one of which is that the validity of devices which are defined by the standard must not be prejudiced.
In Europe, parking conditions are now strictly defined in the new R48-09, and unapproved lamps ‘may be’ or ‘are’ prohibited—the exact degree and nature of prohibition isn’t final; there is an ongoing task force for lamp activation under parked conditions (TF LUQC, as we’ve previously reported). Consensus is not finalized yet and there are different views, so the best way for an automaker to navigate this uncertainty is to be close to their authorities to have their feedback.
Anyhow, in R48-09, this kind of light from the wheel might be considered as a courtesy light, defined as a lamp used to provide supplementary illumination to assist the vehicle user to approach or depart, enter or exit, load or unload the vehicle. But it’s not a free-for-all; there are constraints, one of which is that it should not be possible to see the apparent surface of the courtesy light from 10 metres away and a height of 1 to 3 metres, and lighted wheels as proposed in these photos would seem to run afoul of that requirement, presented in ¶ 6.24.9.3:
(…)the technical service shall perform a visual test to verify that there is no direct visibility of the apparent surface of the exterior courtesy lamps, if viewed by an observer moving on the boundary of a zone on a transverse plane 10 m from the front of the vehicle, a transverse plane 10 m from the rear of the vehicle , and two longitudinal planes 10 m from each side of the vehicle; these four planes to extend from 1 m to 3 m above and perpendicular to the ground as shown (…).
However, ¶ 6.24.9.4 suggests a possibility to disregard that requirement if the light intensity is less than 0.5 cd:
At the request of the applicant and with the consent of the Technical Service, the requirements of paragraph 6.24.9.3. may be verified by a drawing or simulation or deemed be satisfactory if the applicant can prove that the luminous intensity of light emitted directly during the observation test described in Annex 14 is not more than 0.5 cd per lamp.
Now, what about other-than-parked conditions, when the vehicle is actually driving? Then a lamp like this could maybe be considered a manœuvring lamp, which is allowed to be white, but then its apparent surface must not be visible—a requirement similar to 6.24.9.3.On top of that, the lamp would be in this case installed on a movable component.
On top of that, the lamp would be in this case installed on a movable component. ¶ 5.17 says any kind of lamp may be mounted on a movable component of the vehicle, as long as the conditions of ¶ 5.18 through 5.20 are met.
“Rear position lamps, rear direction-indicators and rear retro-reflectors, triangular as well as non-triangular, may be installed on movable components only:”
Would it be acceptable to have another lighting function on a movable part (the wheel) if the component fulfils the photometrical requirement of 5.18.1?
“If at all fixed positions of the movable components the lamps on the movable components meet all the position, geometric visibility, colorimetric and photometric requirements for those lamps”
The only lights intended for dedicated installation on the side of the car—side marker lights—must be amber, not white.
In a nutshell, is it feasible? My personal opinion is perhaps yes, in parking condition and in combination to light intensity below 0.5 cd. We will see when BMW will release the car. Looking forward to discovering it soon!