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Thread: Legal question re: ECE vs DOT lights in Canada

  1. #1

    Default Legal question re: ECE vs DOT lights in Canada

    My understanding is that Canadian regulations (specifically British Columbia if it differs jurisdiction to jurisdiction) allow for ECE-compliant RHT lights to be used. Is this correct?

    Specifically, would it be legal for me to run Cibie Super Oscar LED wide beam lamps as driving lights to augment my high beams? Referring to these lamps here: http://www.ebay.ca/itm/CIBIE-Super-O...dU3glS&vxp=mtr which, if my research is correct, are ECE compliant but not SAE compliant.

    Also, am I correct in believing that the wide beam (rather than the standard beam) would be better for illuminating the sides of the road to spot wildlife in the ditch before they run out in front of me?

    Thanks in advance.
    Michael

  2. #2

    Default Re: Legal question re: ECE vs DOT lights in Canada

    Quote Originally Posted by northbynorthwest View Post
    My understanding is that Canadian regulations (specifically British Columbia if it differs jurisdiction to jurisdiction) allow for ECE-compliant RHT lights to be used. Is this correct?
    That's not a provincial matter, it's at the national level. Under Canada Motor Vehicle Safety Standard 108 and 108.1, ECE headlamps (for right-hand traffic) are legally equivalent to US headlamps. There is no legal preference for one or the other, no constraints on when one type or the other must or may not be used, etc. Individual Canadian provinces and territories are not empowered to ban or require one type or the other. So yes, ECE headlamps for RH traffic are legal in BC.

    Specifically, would it be legal for me to run Cibie Super Oscar LED wide beam lamps as driving lights to augment my high beams?
    That's not germane to your first question. Auxiliary high beams are legally not the same thing as headlamps. There is no legal reason in BC why you can't use these, but they will have to be hooked up correctly (so they can only be lit with the vehicle's high beam headlamps, and if you switch to low beam the aux driving lamps switch off without your having to touch a separate switch).

    which, if my research is correct, are ECE compliant but not SAE compliant.
    True, but not relevant.

    am I correct in believing that the wide beam (rather than the standard beam) would be better for illuminating the sides of the road to spot wildlife in the ditch before they run out in front of me?
    Yes.

  3. #3

    Default Re: Legal question re: ECE vs DOT lights in Canada

    Are 'ECE' bulbs legal in 'DOT' headlamps? Or are only 'DOT' bulbs in 'DOT' lamps and 'ECE' bulbs in 'ECE' lamps legal?

  4. #4

    Default Re: Legal question re: ECE vs DOT lights in Canada

    ... for example, is an 'ECE'-only H4 60W/55W bulb legal in a 'DOT' headlamp whose manufacturer specifies an HB2 60W/55W bulb?
    If not, because of differing bulb type specification, would a (theoretically) 'ECE'-only HB2 bulb be legal in the above-mentioned lamp?

  5. #5

    Default Re: Legal question re: ECE vs DOT lights in Canada

    In Canada there is no legal preference for US-spec or ECE-spec bulbs; Canada Motor Vehicle Safety Standard 108 requires that headlamps (whether US or ECE) be equipped with bulbs designed to conform to specifications:



    (i) of a standard or recommended practice issued by the SAE, or

    (ii) of a regulation issued by the ECE, or

    (iii) of a standard issued by the International Electrotechnical Commission (IEC); or

    (b) provided by the vehicle manufacturer to the [Transportation] Minister, at the Minister’s request.
    Last edited by -Virgil-; 11-07-2017 at 04:01 PM.

  6. #6
    Moderator Alaric Darconville's Avatar
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    Default Re: Legal question re: ECE vs DOT lights in Canada

    Quote Originally Posted by northbynorthwest View Post
    My understanding is that Canadian regulations (specifically British Columbia if it differs jurisdiction to jurisdiction) allow for ECE-compliant RHT lights to be used. Is this correct?
    This is among questions covered in the Vehicle Lighting Laws & Regulations sticky.

    Excerpt from Canada Motor Vehicle Safety Standard 108.1
    108.1 (1) As an alternative to the headlamps required by section 108 of this Schedule, passenger cars, multi-purpose passenger vehicles, buses and trucks may be equipped with headlamps that emit white light and that

    (a) comply with

    (i) ECE Regulation No. 8, Uniform Provisions Concerning the Approval of Motor Vehicle Headlamps Emitting an Asymmetrical Passing Beam or a Driving Beam or Both and Equipped with Halogen Filament Lamps (H1, H2, H3, HB3, HB4, H7, H8, H9, HIR1, HIR2 and/or H11), as amended from time to time,

    (ii) ECE Regulation No. 20, Uniform Provisions Concerning the Approval of Motor Vehicle Headlamps Emitting an Asymmetrical Passing Beam or a Driving Beam or Both and Equipped with Halogen Filament Lamps (H4 Lamps), as amended from time to time,

    (iii) ECE Regulation No. 31, Uniform Provisions Concerning the Approval of Halogen Sealed-beam Unit (HSB Unit) Motor Vehicle Headlamps Emitting an Asymmetrical Passing Beam or a Driving Beam or Both, as amended from time to time,

    (iv) ECE Regulation No. 98, Uniform Provisions Concerning the Approval of Motor Vehicle Headlamps Equipped with Gas-discharge Light Sources, as amended from time to time, or

    (v) ECE Regulation No. 112, Uniform Provisions Concerning the Approval of Motor Vehicle Headlamps Emitting an Asymmetrical Passing Beam or a Driving Beam or Both and Equipped with Filament Lamps, as amended from time to time;

    (b) despite the requirements of the ECE Regulations referred to in this section, are set to be used on vehicles designed to travel on the right-hand side of the road;
    (Excess trimmed)
    And, yes, (b) means the lamps MUST be for right hand traffic as you'd already posited.

  7. #7

    Default Re: Legal question re: ECE vs DOT lights in Canada

    Quote Originally Posted by -Virgil- View Post
    HB2 is not an ECE bulb, it is a US specification
    Theoretically, can't a bulb be marked 'HB2', be also marked 'H4', be also marked with an ECE mark, but be not marked 'DOT'? Theoretically

    Anyway,

    From TSD No. 108, Revision 5R, "Lighting System and Retroreflective Devices (Standard 108)": (bolding mine)
    S7.7 Replaceable light sources
    Each replaceable light source shall be designed to conform to the dimensions and electrical specifications specified or provided in accordance with subsection 108(5) of the MVSR, and shall conform to the following requirements:
    (a) If other than an HB Type, the light source shall be marked with the bulb marking designation specified or provided in accordance with subsection 108(5) of the MVSR. The base of each HB Type shall be marked with its HB Type designation. Each replaceable light source shall also be marked with the symbol DOT and with a name or trademark in accordance with paragraph S7.2.
    From TSD No. 108.1, "Alternative Requirements for Headlamps": (ellipses mine)
    108.1 (1) As an alternative to the headlamps required by section 108 of this Schedule, passenger cars, multi-purpose passenger vehicles, buses and trucks may be equipped with headlamps that emit white light and that
    (...)
    (f) are fitted with bulbs that conform to

    • (i) a document referred to in paragraph 108(5)(a) or the information provided pursuant to paragraph 108(5)(b), and
    • (ii) paragraphs S7.7 of TSD 108, except that the “DOT” symbol referred to in paragraphs S7.7(a) and (e)(7) is not required;
    So, all replaceable bulbs have to have the symbol 'DOT', unless they are bulbs for headlamps specified in TSD 108.1, which, as far as I can tell, are ECE headlamps. Is that not correct? If it is not correct, why?

    Basically, if I have a headlamp for which an HB2 bulb is specified (in the owner's manual of the car -- I could not find any DOT, SAE, ECE, or bulb type markings on the lens, and I have yet to look at other parts of the lamp), can I, legally, use an H4 (no DOT mark, no HB2 mark, but with an ECE mark) bulb?
    Last edited by mikecz; 11-07-2017 at 04:08 PM.

  8. #8

    Default Re: Legal question re: ECE vs DOT lights in Canada

    Quote Originally Posted by mikecz View Post
    Theoretically, can't a bulb be marked 'HB2', be also marked 'H4', be also marked with an ECE mark, but be not marked 'DOT'?
    A bulb that is marked "HB2" must also be marked "DOT". HB2 is a US specification with tighter filament position and focus tolerances than the ECE H4 specification. Practically all HB2 bulbs meet the H4 spec (and most HB2 bulbs are also type-approved as ECE H4), but not all H4 bulbs meet the HB2 spec.

    From TSD No. 108, Revision 5R, "Lighting System and Retroreflective Devices (Standard 108)"
    That is not the correct document to answer the question you asked.

    So, all replaceable bulbs have to have the symbol 'DOT', unless they are bulbs for headlamps specified in TSD 108.1, which, as far as I can tell, are ECE headlamps. Is that not correct?
    No, that is not correct.

    Why?
    Because the correct answer is the one I provided earlier in this thread, which is taken from CMVSS 108 (5) and CMVSS 108.1 (1) (f) which you can view here (search the page for All the information regarding every type of bulb and then for are fitted with bulbs that conform to). There is no requirement for "DOT" on bulbs or E-code markings on headlamps or bulbs in Canada, though most of them are marked because US and ECE regs do require markings.
    Last edited by -Virgil-; 11-07-2017 at 04:12 PM.

  9. #9

    Default Re: Legal question re: ECE vs DOT lights in Canada

    A headlamp I have incorporates in it a replaceable light source (a bulb), and it is specified as HB2 (a DOT bulb). I am not allowed to change the bulb type specification for the lamp, I would figure, so if the manufacturer specified HB2, then I cannot use an H4 bulb to replace the HB2 that was installed in the lamp originally. Correct? If not, why?

  10. #10

    Default Re: Legal question re: ECE vs DOT lights in Canada

    No, that is not correct, though HB2 ("9003") bulbs are easier to buy than H4 bulbs in Canada. You have now asked your question three different ways and gotten the same answer, worded three different ways. Please don't ask a fourth time; the answer is not going to change, so let's consider that question answered. Done and done. Other questions are welcome, but if you want to pursue this conversation, please clue us into what's got you all worked up about this, exactly. Are you worried a policeman or insurance adjustor would ding you for H4 instead of HB2 bulbs? If so, rest easy, because that's not going to happen. Is there a specific bulb you have your eye on that you'd like to try, but it's H4 instead of HB2? If so, please tell us details about the bulb. If it's something else, go ahead and spit it out.
    Last edited by -Virgil-; 11-07-2017 at 05:13 PM.

  11. #11

    Default Re: Legal question re: ECE vs DOT lights in Canada

    I still don't understand how you arrived at your interpretation of those CMVSS rules, but if an H4 can be used in the place of an HB2 in Canada 100% legally, that's great.

  12. #12

    Default Re: Legal question re: ECE vs DOT lights in Canada

    There is no interpretation required; the language is clear. What's necessary is to understand the regulations well enough to know which language applies to the question you asked, is all.

  13. #13

    Default Re: Legal question re: ECE vs DOT lights in Canada

    If you were to explain how it is legal to substitute one bulb type for another, with reference to the above mentioned regulations, if applicable, that might help me understand the matter better.
    Surely you can't use just any bulb referred to by 108 (5) to replace any other? You can't replace an H4 with an H7, etc? So what makes the HB2 and the H4 equivalent in the eyes of the law?
    Sorry, I just don't understand.
    Last edited by mikecz; 11-07-2017 at 07:44 PM.

  14. #14

    Default Re: Legal question re: ECE vs DOT lights in Canada

    Quote Originally Posted by mikecz View Post
    Surely you can't use just any bulb referred to by 108 (5) to replace any other? You can't replace an H4 with an H7, etc?
    No, you can't, because it is physically impossible to do so. Therefore no reason to have any law against it.

    So what makes the HB2 and the H4 equivalent
    Please refer to post #8 in this thread. :-)

  15. #15

    Default Re: Legal question re: ECE vs DOT lights in Canada

    You left out "in the eyes of the law" when you quoted my question. I don't see how Post #8 answers that. They might be even the same bulb, but when you put in an H4 only marked bulb into a lamp that specifies an HB2 only, how can you be sure it conforms to the HB2 spec? The manufacturer does not tell you that.

  16. #16

    Default Re: Legal question re: ECE vs DOT lights in Canada

    Post #8 (following on from post #5) does indeed answer that question directly, and even points you to the correct paragraphs in the correct regulations. In Canada, vehicle makers are allowed to specify and install bulbs according to any of the specifications listed.

    That said, you (as a vehicle owner/driver) are not under the control of the Canada Motor Vehicle Safety Standards, which apply to manufacturers and importers of vehicles and vehicle equipment (parts). Your actions regarding headlamps are governed by the laws on the subject, if any, of your province or territory.

    For the last and final time: there is no legal consequence if you install an H4 bulb instead of an HB2. Not only is there no mechanism for a legal consequence, but provinces and territories aren't allowed to have standards more stringent than the national standard. It works the same way in the US; states can't have vehicle equipment standards that are stricter than the Federal standard. In this case, the Canadian national standard says "Headlight bulbs according to technical standards published by any of the following bodies/methods are fine", so provinces and territories aren't allowed to enact a requirement that you can only use SAE bulbs in SAE headlamps or you can only use ECE bulbs in ECE headlamps, etc.

    You are worrying about a non-issue.

  17. #17

    Default Re: Legal question re: ECE vs DOT lights in Canada

    Thanks for the clarifications.

    Your actions regarding headlamps are governed by the laws on the subject, if any, of your province or territory.
    Might not those prevent a person from 'modifying' a part on the car, prevent them from using a component (sub-part) type not used/specified by the manufacturer/importer, even if that component were to be ok to be used in another CMVSS compliant assembly? Couldn't people technically modify their lamps to put, say, two bulbs in the place of one, which obviously would not work well, to say the least? Or, use an H4 that is outside the tolerance of HB2 in a headlamp that came with and specifies an HB2, that would make the whole headlamp not be in accordance with CMVSS (not that it would be applicable in that case as you say), something a provincial government might not want?

    provinces and territories aren't allowed to have standards more stringent than the national standard.
    These laws might not be a standard that is more stringent, they might not even refer to standards, but simply forbid the use of component types not used/specified by the manufacturer/importer of the assembly, no?

    "Headlight bulbs according to technical standards published by any of the following bodies/methods are fine"
    ...as part of an assembly that (in whole, not the enclosure and bulbs separately) complies with the CMVSS, from what I understand?

    Aside from all of that, is it even possible to put an H4 (as far as possible outside of the tolerances of HB2 but still within the tolerances of H4), into an HB2 enclosure, and have the headlamp not be compliant with CMVSS?


    Anyway, perhaps this has become more of an academic discussion than a practical one, but I'm curious. If you'd rather not continue discussing this though, that would be fine with me.

  18. #18
    Moderator Alaric Darconville's Avatar
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    Default Re: Legal question re: ECE vs DOT lights in Canada

    Individuals are not regulated parties under the respective Federal laws; and some of the limits on them under State or Provincial laws may not always be enough, let alone readily apparent.

    People can "technically" do all kinds of things that can add up to them being found at fault when their modification gets themselves or someone else killed or injured.

    This has gone on long enough; it's not productive to continue.

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