When it comes to headlight technology, the U.S. and its Federal Motor Vehicle Safety Standards (FMVSS) regulations have always been slow to adapt, which has kept systems like the Adaptive Matrix Headlights on the non-U.S. 2014 Audi A8 sedan from illuminating our roads. When the rest of the world was enjoying the latest features and lighting roadways up with adaptive beams that could do things like selectively dim individual bulbs to avoid dazzling pedestrians or oncoming drivers, we were stuck with stone age non-adaptive headlights. This isn’t new; when the world was enjoying replaceable halogen bulbs as early as 1967, the U.S. was still utilizing sealed-beam headlights. In fact, the H1 bulb wouldn’t even be approved for use in America until 1997. Yes, we were that backwards.
Now it seems that thanks to the new infrastructure bill passed by Congress and signed into law, we’re finally going to start seeing updated headlights on U.S.-market automobiles. Let’s talk briefly about what we started with, what we currently use today, and why that’s potentially a huge deal. We’ll also touch on LED lights and how they are both legal and illegal at the same time.
Highlights of Headlights
When the “horseless carriage” was first introduced to the public, we borrowed what we knew from the, er, horsed carriages to light the way ahead, but problems emerged quickly when automobiles started hitting speeds faster than horses could pull. We literally outran the carriage light, as it didn’t provide enough forward light to drive safely. Electric lights were installed on cars as early as 1898, but use was limited due to filaments that rapidly burned out and dynamos that didn’t produce enough electricity for sufficient power. It wouldn’t be until 1908 and the introduction of the Peerless that headlights would become standard.
“Dipping” headlights, a.k.a. low-beam lights, would be introduced in 1915 but not made standard until 1917 thanks to Cadillac. This lowering of the driving light was done by physical lever until 1924 when BiLux created the first bulb with a low- and high-beam filament inside a single bulb. In the United States in 1940, a requirement of a single, seven-inch round sealed-beam headlight per side was made and locked us into this standard until 1957 when smaller, 5.75-inch sealed-beam lights were allowed. Then in 1974, American cars were allowed to have rectangular sealed-beam headlights. The U.S. was stuck with these units’ poor light quality until the 1980s, when replaceable halogen bulbs in matching housings were permitted. The 1990s finally saw High Intensity Discharge (HID) lights on the BMW 7 Series and the 1996 Lincoln Mark VIII.
Meanwhile, the rest of the world enjoyed many advancements in headlight technology, with most going into legal production abroad just as soon as they were available. Thus, the U.S. was always a step behind. When America was stuck with sealed beams, the world had moved on to replaceable bulbs. When the world was taking advantage of LED lights, America was restricted to halogen lights. Ah, but what about LED lights in the U.S., both aftermarket and OEM? Well, that’s a problem.
OEM LEDs in the US
LED lights are not illegal, except where the headlight is concerned. You may use LEDs in unregulated auxiliary lights. Side markers are A-OK. Brake lights? You’ll potentially blind the driver behind you, but they are legal. Fog lights are also fine, as are those super-bright LED off-road lights you installed on your mall crawler. However, when it comes to the lights that work as your main forward illumination in the U.S., they must remain sealed beam, HID, or replaceable halogen bulbs in a housing as fitted from the factory.
Aftermarket LED Lights
Yes, LED replacements are available via the aftermarket. Installing them is technically modifying your headlights and not allowed by national law through FMVSS. Yes, you only changed the bulb, but the headlamp no longer conforms to factory—i.e. legal—specs.. The reflector and lens of American vehicles’ headlights are designed to work with those halogens, which is why using an LED replacement bulb is both illegal and typically results in crappier lighting than the OEM units.
Before you suggest changing over to an OEM LED housing, that’s potentially illegal as well. If it doesn’t have DOT or SAE markings on the part, that would also be considered an illegal modification according to FMVSS. However, it’s also federally illegal to swap an LS7 into your Mazda MX-5 but federal law really hasn’t stopped that from happening. Sort of.
What the Infrastructure Bill Adds
While it’s potentially not going to change what’s illegal now, as far as installing that Euro-legal LED headlight housing into your otherwise U.S.-legal Audi R8, the door is opening to allow for more technology forward lighting to be introduced in America. As reported by The Drive, section 24212 of HR 3684—the Infrastructure Investment and Jobs Act and signed into law on November 16, 2021—is simply titled “Headlamps.” and states, “Not later than 2 years after the date of enactment of this Act, the Secretary shall issue a final rule amending Standard 108.”
Standard 108 refers to is the part of the FMVSS that mandates all lighting on all federally legal vehicles and is titled “Lamps, reflective devices, and associated equipment.” These rules not only dictate what colors lamps must be and where they must be used, but also what types of headlight technologies are legal on U.S.-market vehicles.
It’s More Than Just What Headlights to Use
However, the amending of Standard 108 dictated in the infrastructure bill could affect more than just allowing better adaptive headlights—as we’ve seen from Audi and its Digital Matrix Headlight system—as the passage covers everything from testing procedures to design to function, which is why you can’t turn on your high beams on with any other forward light operating. This means the FMVSS will now be required to set new guidelines within two years that meet the Society of Automotive Engineers (SAE) J3069 standard that “provides test procedures, performance requirements, and design guidelines for adaptive driving beam (ADB) and associated equipment.” There is currently no stated design parameter or testing procedure for adaptive lights in Standard 108—despite one having been adopted by the SAE in 2016—and why, technically, many ADBs are not legal in the U.S.
With new rules in place, there still won’t be a Wild West of headlights and you probably still won’t be able to legally swap halogens for LEDs, but it will finally bring the U.S. up to date with current headlight technology. Of course, as history has shown, staying up to date is another story.
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