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Discussion Starter · #1 ·
I wanted start a specific discussion regarding North American vs. European (and ROW) vehicle standards, particularly lighting standards. There's a thread rear bumper lights! | Jeep Renegade Forum that began as a discussion of aftermarket combination back-up lights and rear fog lights for the Renegade, which I think is interesting in itself. But that thread then veered off (thanks significantly to me) to a discussion of lighting standards in general, particularly headlights. There seemed to be some interest in that (unless rsanges was being sarcastic), so I'm starting a new thread.

Plus there seem to be a lot of Europeans who are importing North American-spec Renegades to Europe, and I thought it might be worthwhile to discuss the differences in standards and which components might have to be modified in order to meet European regulations.

I'm most familiar with German standards, since I've been stationed there over ten years of my life in the military. My cars didn't have to meet German standards because of the status of Forces Agreement (SOFA), but I was very aware of German regulations and tired to conform to them anyway. that's the European country. I believe that the rest of Europe largely follows the German example as far as vehicle standards; in any case, German regulations wouldn't be contrary to EU regulations.

Anyway, picking up from that other thread... Regarding my Trailhawk's OEM LED headlights, sgt_raffie, in Poland, wrote:

Yes. Asymetic beam pattern is requried and I cant remember owning a car without asymetric headlight. Even the old Polonez I had as a first car had asymetric headlights. The cut off "style" is less of an issue, its the direction of the beam which has to go to the "offside" and light up the curb. And this is quite a thing when inspections are carried out.
Sorry, but I'm still not convinced. I do agree, of course, that pretty-much all vehicles in Europe have had headlights with asymmetric beams for many decades now. But I don't think that's an actual standard, law, or regulation anywhere.

Example: In Germany, as far as I know, the regulation for motor vehicles is the StVZO (Straßenverkehrs-Zulassungs-Ordnung, or Road Traffic Licensing Regulation). That gives all sorts of requirements for vehicle equipment that's going to be used on public roads.

Section 50 of the StVZO applies to headlights for high- and low beams. § 50 StVZO – Scheinwerfer für Fern- und Abblendlicht – LX Gesetze.

Among other requirements, it gives the requirement for light intensity with headlights. For high beams, the light has to be at least 1.00 Lux at a distance of 100 meters for most vehicles.

It also specifies that low beams have to have a horizontal cut-off at the height of the headlight centers, so that the light above that cut-off is no greater than 1 Lux at a distance of 25m. That explains the sharp cut-off with ECE headlights, and reflects :) the European aversion to glare.

The only mention of asymmetric headlight beams is in the last part of sub-paragraph (6):

"As far as headlights with asymmetric low-beam light is concerned, the 1-Lux boundary may rise up at an angle of 15 degrees to the right from the point corresponding to the headlight center, as long as something different is not specified in international agreements or regulations."

So the Germans don't require asymmetric headlights; they just require that if headlights are asymmetric, the cut-off has to go up to the right of center at a 15-degree angle.

I do see the caveat that international agreements or regulations can overrule this. I'd be interested to see whether there are any EU regulations regarding this (citation, please...).

 

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Marek.
There are NO international regulations in Europe as to vehicle inspections. Member-state laws take precedence as these are infinitely more precise than the minimums set by the EC in their Directives. All the rest is in the hands of member countries. I`m not discussing regulations for newly manufactured cars as this is another matter and a very complicated one. The moment I purchase I vehicle and take it to my local inspection place I`m bound by Polish law in general and 2 documents I mention below in particular.
Also remember that, in general, member-states have to accept the EC Directives and incorporate these in their own laws. EC Directives are exactly what it says on the tin. A Directive, not a law. For example, there was a recent (2021) Directive concerning firearms. Among other limitations, there were limitations to magazine sizes introduced. The Czech Republic (as a very pro-gun country) decided not to follow this.

I was mistaken last time when I mentioned the Vienna convention for agreement on this. Viena convention (one of anyway) regulated the cross-acceptance of driving licenses. The cross-acceptance of inspection testing was done in one of the Geneva conventions (1958 as far as I recall).

I know that where I live, in Poland, there are two main documents which deal with this matter. These are:
  • Ustawa Prawo o Ruchu Drogowym (w skrócie PoRD) Dz.U. 1997 nr 98 poz. 602
  • Rozporządzenie w sprawie warunków technicznych pojazdów Dz.U. 2015 poz. 305
If You look thorugh those You will come to this conclusion:
Światła mijania powinny być asymetryczne i oświetlać drogę po prawej stronie na większą odległość niż po lewej stronie. (Dipped beam should be assymetric and light up the right side of the road further then the left side).

Full beams should be symmetric and light up the road ahead equaly.

I also know that it IS a requirement for such light to be fitted. Unless You own a "museum piece" or other "special" vehicle which has been allowed, by the Minister of Transport (he can allow for exemptions in these matters), not to meet the requirements, You need to have asymmetric lights. Otherwise, You won`t pass the inspection.

But this all hinges on a simple thing that there are no universal laws in Europe concerning the inspections and required equipment (for example some countries require You to have spare bulbs in the car while others don`t).

Another subject we broached was the requirement for a visible indicator of fog lights. As it stands now there is no such requirement in Poland. Document called Rozporządzenie w sprawie warunków technicznych pojazdów Dz.U. 2015 poz. 305 precisely describes that for a full beam, the indicator light is mandatory and has to be blue. For dipped beam the indicator light is NOT mandatory, and if fitted it has to be green and non-blinking. Position lights require a green, non-blinking indicator. Indicators require the indicator :), it has to be green and blinking, etc. There is NO mandatory indicator for fog lights, front or rear mentioned anywhere.
 

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Discussion Starter · #3 ·
OK, that's really interesting... I would have thought that a vehicle legal to own and register in one EU country, would also be legal to own and register in other EU countries. Otherwise what's the EU good for? ;) I'm not talking about whether you've got a first aid kit or fire extinguisher or colored vest or something.... I'm talking about the permanent OEM equipment on your vehicle.

Like I said, it's kind of a moot point because these days pretty-much all European headlights are asymmetrical.

However, note that in Polish, "powinny" means plural "should." That's quite different than "will" or "must." (I know, because I was a DoD policy guy for many years; and words like that are extremely important in the context of policy.)

I guess things have to be defined. Over here, a "DoD Directive" is absolutely mandatory, to the point of legal obligation. DoD Directives use words like "shall," meaning you legally must (or must not) do something; and policy offices at that level are extremely careful that other issuances giving flexible guidance never use that wording.

So that means that in regard to vehicle lighting, Germany seems to be stricter that Poland in most things. But in some, Poland is (or may be) stricter... o_O

How about you guys in other European countries (to include the UK)?
 

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Registration issues for example: A LOT of vehicles from Scandinavia have extra spotlights fitted. Legal pretty much anywhere in Scandinavia. In Poland - not so much. You either have to cover them of remove. I`m oversimplifying a bit but not a lot.
You are 100% correct with "powinny" and "muszą". However, this stands as is. Most of the Polish law is...hmm...ambiguous...
I do a lot of "shall" when specifying building projects ":D. I love English as in my opinion it`s a very precise language, great for technical descriptions.
What good is the EU for? Let`s not go down this particular hole. It`s rather shallow :D. As I stated before. Damned if You do, damned if You don`t..
As to strictness of laws - You got it. But if I`m legal in Poland I`m legal in all signatories of the 1958 Geneva Convention.
 

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Discussion Starter · #5 ·
I just took another close look at my LED headlights. Nope, no E-Code on them anywhere that I can see.

I'd love to hear from anyone in Europe with the optional LED headlights -- not sure how common those are over there. Not so common here, thought they should be.

Interestingly, in back, the back-up lights/rear reflectors (which I have on both sides of my bumper; because rear fog light isn't mandatory here, and I have all-red LED tail lights) have an E3 code (Italy -- what a surprise!!):

2396352264


The front turn signals have an E9 code, for Spain:

2396352266


But the front fog lights -- LED projectors, like the headlights -- don't have an ECE code. Just SAE and... CCC. They're made by Valeo, but it doesn't say where.
 

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Beam patterns and tolerances are specified in countries' annual or bi-annual vehicle inspections.

Things differ from country to country

Some cars with projector headlamps come with a shutter to "flatten" the kick-up on the nearside/kerbside when driving on the opposite side of the road.

Many newer HID headlamps now have a flat pattern to avoid this issue.

There is other stipulation like rear fog(s) compulsory in all European countries but not in Japan. (Or US?) meaning they need tobe fitted when importing from those countries.


Many a grey-import MX5/Miata with an old style fog hanging off the rear bumper.
 

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Discussion Starter · #7 ·
Some cars with projector headlamps come with a shutter to "flatten" the kick-up on the nearside/kerbside when driving on the opposite side of the road.
You mean if you're a Brit (or Maltese, or whatever), and you want to drive your car on the Continent?

Yes, many projector shutters can be adjusted to get rid of the kick-up on the curb [sic] side.

On "conventional" reflector headlights, where the beam pattern is formed by the outside lens, I'm sure you still have to cover the "kick-up" area on the lens with a triangle of black tape...

Many newer HID headlamps now have a flat pattern to avoid this issue.
OK, so that's exactly the issue I'm discussing with sgt_raffie. The optional OEM bi-LED headlights on my 2021 U.S.-spec Trailhawk have exactly that kind of beam pattern. Very sharp cut-off, but no kick-up -- straight all the way across. Seems like they would be legal in Germany (the way I read the StVZO), though apparently not in Poland. Yet my headlights -- made by Automotive Lighting (Magnetti Marelli) I assume in Italy -- don't have an ECE code on them...

There is other stipulation like rear fog(s) compulsory in all European countries but not in Japan. (Or US?) meaning they need tobe fitted when importing from those countries.
That's correct; no rear fog light mandatory in the U.S. (or Canada or Mexico). Very rare to see them here, except on Land Rovers, Audis, Volvos, Saabs, and such. Unfortunately, Americans who have them don't know the first thing about what they are. Specifically when NOT to use them... :mad:

Several years ago, in Ohio, I'd see the same woman in the same expensive Land Rover, commuting in to Wright-Patterson Air Force Base several dark but clear mornings in a row, with rear fog lights (two of them on the LR) blazing. I'd somehow end up right behind her each day, blinded by the light. One morning I followed her into her parking lot (yes, looked like stalking), and nicely asked her whether she knew she had her rear fog lights on. She just gave me a genuine blank look. So I showed her the lights on the back, and the switch that turned them on and off. Yes, the switch would turn off automatically whenever the headlights were turned off; so she had to be consciously turning the rear fog lights on again each morning. She genuinely had no idea; I think she was just turning on every light she had available. Typically American, I'm afraid...

Many a grey-import MX5/Miata with an old style fog hanging off the rear bumper.
Yes. The Germans don't require rear fog lights on "classic" cars built before 1991. But anything imported (like from the U.S.) after 1991, if it doesn't have a rear fog light, has to have one added. Usually the only place to legally add one is hanging off the bottom of the rear bumper. I had one on my 1976 Toyota Corolla when I was stationed in Germany, though it was pre-1991 and I didn't need one as a G.I. in any case. They're horribly tough to keep aligned correctly...
 

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My 2016 Trailhawk is a RHD import to Japan.
The headlights have the sharp kick up but to the left as that would be the curb side, My wife's 2020 Suzuki SX-4(built in europe) also has the same pattern. They both also have a manual adjustment next to the switch for headlight height which became mandatory on JDM cars around 2009.

Since the turn signals are required to be amber they are in the center portion of the tail lamps (I believe that's where the reverse lights are on US models)
For the rear fog it is not mandatory in Japan but if your vehicle is equipped with one it needs to be operational. I saw the lights in the other thread and ordered them as I would like to have reverse lights on left and right the only thing I'll encounter is the loss of the red reflector that surrounds both the fog and reverse lights as they are a requirement so if I do install the other lights I'll either have to switch back for bi-annual inspection or stick on some reflectors.
 

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Discussion Starter · #9 ·
My 2016 Trailhawk is a RHD import to Japan.
The headlights have the sharp kick up but to the left as that would be the curb side ... They both also have a manual adjustment next to the switch for headlight height
So that's the same as Europe now.

But those are the standard halogen reflectors, right? Are they any good? Because the ones on the U.S. Renegades are kind of crappy, not surprisingly...

I'm actually curious about the optional bi-LEDs in Europe...

Since the turn signals are required to be amber they are in the center portion of the tail lamps (I believe that's where the reverse lights are on US models)
Yes, but again that's with the halogen reflector headlights. With the bi-LED headlights I've got, the tail lights are also LED, and all red (which I hate -- I really do prefer amber turn signals). And the two lights in the rear bumper are the reverse lights.

For the rear fog ... I saw the lights in the other thread and ordered them as I would like to have reverse lights on left and right
So your Trailhawk is a UK model, with a rear fog light on the right (driver's) side, and reverse light on the left?

I'd be curious to hear how these aftermarket lights work for you. So you want to get rid of the rear fog light, and have a reverse light on each side? I'm not sure that's easily possible. Right now you've only got )I'm sure) two wires to each light -- +12v and ground. And the computer is sending the rear fog light signal to one, and the reverse signal to the other. So you'd need to figure out how to re-code the computer; or do some jury-rig re-wiring...

the only thing I'll encounter is the loss of the red reflector that surrounds both the fog and reverse lights as they are a requirement so if I do install the other lights I'll either have to switch back for bi-annual inspection or stick on some reflectors.
Yeah, those are the only rear reflectors you've got. If those new lights don't have reflectors, I'm not sure stick-on reflectors will pass inspection. Stick-on reflectors alone aren't legal in many/most/all U.S. states, but we don't have to worry about stringent inspections. I imagine the Japanese are stringent...

You've got a U.S. flag in your profile. Are you stationed in Japan with the military?
 

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The headlights are Xenon/ Projector type
Fog light is on the right (drivers side) the aftermarket ones are both reverse (white center) and fog (red Led surround) I'll probably need to figure out an adapter harness so I can have both Fog and Reverse on both sides.
stick on reflectors actually do pass for inspection here as we've been doing it on Non JDM cars for years as long as the surface area meets the minimum requirements.
 

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Discussion Starter · #11 ·
So, are you a GI stationed there? If so, who does your inspections?

Each time I was stationed in Germany, under the SOFA we didn't have our vehicles inspected by the German TÜV, like anyone else would have to. Instead our cars were inspected by "local-national" German inspectors working for our Army Facility Engineers. Theoretically the same standards (with exceptions for U.S. lighting and such). I don't know if they were more or less strict than the TÜV inspectors...
 

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Not on active duty anymore but have worked here for the Marine Corps for 20+ years been living here since 88
For SOFA people the vehicle can be inspected by either the on base inspection station (AAFES run but final inspection from local Transport Authority) or at an off base certified inspection station.
 
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