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Requirements for Xenon Headlights? (Possible Solution)


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Hi There

I went through a rabbit hole of reading about Xenon headlights and the ADR regulations for having them installed. As people have been defected by running factory xenon I was researching in ways to make them compliant. Everyone always say needs to be self leveling and have washer installed, which I don't necessarily agree with. For this argument I'm using R34 as reference as I'm more aware on the construction of the headlight compared to the R33 Xenon, which may still be the exact same case.

 

For the self leveling clause taken from ADR 13 - Installation of Lighting and Light Signalling Devices on other than L-Group Vehicles

Quote

   Headlamp levelling device

6.2.6.2.1.              In the case where a headlamp levelling device is necessary to satisfy the requirements of paragraphs 6.2.6.1.1. and 6.2.6.1.2., the device shall be automatic.

6.2.6.2.2.              However, devices which are adjusted manually, either continuously or non-continuously, shall be permitted, provided they have a stop position at which the lamps can be returned to the initial inclination defined in paragraph 6.2.6.1.1. by means of the usual adjusting screws or similar means.

These manually adjustable devices shall be operable from the driver's seat.

Continually adjustable devices shall have reference marks indicating the loading conditions that require adjustment of the dipped-beam.

The number of positions on devices, which are not continuously adjustable, shall be such as to ensure compliance with the range of values prescribed in paragraph 6.2.6.1.2. in all the loading conditions defined in Annex 5.

For these devices also, the loading conditions of Annex 5 that require adjustment of the dipped-beam shall be clearly marked near the control of the device (Annex 8).

As you can see the bold text "these manually adjustable devices from driver seats" are fine to use. As Series 1 Xenon model headlights do have a 4 level adjuster on the right near the ignition (however not series 2) then these model are consider compliant in that argument.

 

For the Self Cleaning aspect of this argument clause taken from ADR 13 - Installation of Lighting and Light Signalling Devices on other than L-Group Vehicles

Quote

6.2.9.                             Other requirements

The requirements of paragraph 5.5.2. shall not apply to dipped-beam headlamps.

Dipped-beam headlamps with a light source or LED module(s) producing the principal dipped beam and having a total objective luminous flux which exceeds 2,000 lumens shall only be installed in conjunction with the installation of headlamp cleaning device(s) according to Regulation No. 45.[12]

With respect to vertical inclination the provisions of paragraph 6.2.6.2.2. above shall not be applied for dipped-beam headlamps with a light source or LED module(s) producing the principal dipped beam and having an objective luminous flux which exceeds 2,000 lumens.

Now i can understand the argument that Xenon will need a washer as they are over 2000 lumens, but I clicked on the 12 at the end of that sentence and it takes me to the end notes which states

Quote

[12] Contracting Parties to the respective regulations can still prohibit the use of mechanical cleaning systems when headlamps with plastic lenses, marked "PL", are installed.

R34 for headlight lenses are plastic, not sure if PL is mark as I don't currently have my skyline to confirm that marking is there. But could you not technically get a lenses with the PL marking on it and then get away with the argument that you need a washer.

I went through a quick read of the adr and might have missed something else that may cause them to be non-complaint. 

 

But wouldn't these technically be complaint headlights

 

Would love to hear other people input on this and shed some light

 

Edit

In regard to the the washer portion I might be mistaken ADR 45 (which I believe is Regulation NO.45) states 12 cd (candela) I dont understand that portion in regarding to calculating the candela if anyone can shed some light.

Otherwise I guess throw in a washer for the headlight and you definitely comply.

Edited by rahilp
6 minutes ago, GTSBoy said:

What do these say?

     Vertical orientation

 

6.2.6.1.1. The initial downward inclination of the cut off of the dipped-beam to be set in the unladen vehicle state with one person in the driver's seat shall be specified within an accuracy of 0.1 per cent by the manufacturer and indicated in a clearly legible and indelible manner on each vehicle close to either headlamp or the manufacturer's plate by the symbol shown in Annex 7.

 

The value of this indicated downward inclination shall be defined in accordance with paragraph 6.2.6.1.2.

 

6.2.6.1.2. Depending on the mounting height in metres (h) of the lower edge of the apparent surface in the direction of the reference axis of the dipped beam headlamp, measured on the unladen vehicles, the vertical inclination of the cut off of the dipped- beam shall, under all the static conditions of Annex 5, remain between the following limits and the initial aiming shall have the following values:

 

h < 0.8

 

Limits: between 0.5 per cent and 2.5 per cent

 

Initial aiming: between 1.0 per cent and 1.5 per cent

 

0.8 < h < 1.0

 

Limits: between 0.5 per cent and 2.5 per cent

 

Initial aiming: between 1.0 per cent and 1.5 per cent

 

Or, at the discretion of the manufacturer,

 

Limits: between 1.0 per cent and 3.0 per cent

 

Initial aiming: between 1.5 per cent and 2.0 per cent

 

The application for the vehicle type approval shall, in this case, contain information as to which of the two alternatives is to be used.

 

h > 1.0

 

Limits: between 1.0 per cent and 3.0 per cent

 

Initial aiming: between 1.5 per cent and 2.0 per cent

 

The above limits and the initial aiming values are summarized in the diagram below.

 

For category N3G (off-road) vehicles where the headlamps exceed a height of 1,200 mm, the limits for the vertical inclination of the cut-off shall be between: -1.5 per cent and -3.5 per cent.

 

The initial aim shall be set between: -2 per cent and -2.5 per cent.

So, if the headlights' cutoff behaviour (angles, heights, etc) are not as per 6.2.6.1.1 without automatic levelling, then you have to have to have automatic** levelling. Also, if the headlight does not have the required markings, then neither automatic nor manual adjusters are going to be acceptable. That's because the base headlight itself does not meet the minimum requirement (which is the marking).

** with the option of manual levelling, if the headlight otherwise meets the same requirements as for the automatic case AND can be set to the "base" alignment at the headlight itself. So that's an additional requirement for the manual case.

So, provided that the marking is on the headlight and there is a local manual adjustment back to "base" on the headlight, then yes, you could argue that they are code compliant. But if you are missing any single one of these things, then they are not. And unlike certain other standards that I work with, there does not seem to be scope to prepare a "fitness for purpose" report. Well, I guess there actually is. You might engage an automotive engineer to write a report stating that the lights meet the performance requirements of the standard even if they are missing, for example, the markings.

 

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