I thought LED headlight replacement bulbs were still illegal (even in Canada)

JustAnOldFashionedLEDGuy

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Apr 13, 2020
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This would be a question for Virgil.

The two largest automotive aftermarket parts retailers in Canada, (Canadian Tire/Part Source, and NAPA), are both advertising Sylvania EVO LED headlight bulbs for use in pretty much any car they will fit. I have not seen the store packaging, but the website packaging does not indicate the previous FOG/Power Sport designation.

https://www.canadiantire.ca/en/search-results.html?q=sylvania LED headlights

https://www.napacanada.com/en/p/SYLSYLH7LEDBX2?impressionRank=2

What is up with that? I thought Canadian laws on this were somewhat harmonized with the US?
 

-Virgil-

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Unlike US law, where any and all vehicle equipment -- replacement parts, upgrade/modification parts, etc -- physically capable of being installed on a road-going vehicle must meet any and all applicable Federal Motor Vehicle Safety Standards, the Canadian Motor Vehicle Safety Standards (CMVSS) and their enabling legislation do not cover replacement equipment. I've seen instance after instance like these in your links, including a photo someone sent me of a Philips retail display where it claimed the bulbs "meet all CMUSS standards". Which means nothing, because there's no such thing as "CMUSS"; obviously one or more layers of ignorant boob dreamed up that promotional blurb. But even if they'd gotten it right (CMVSS), it would still be wrong. The applicable CMVSS is No. 108, and it requires bulbs that comply with the US regulations or with applicable UN Regulations, and there are no LED retrofit bulbs that meet those regs. What the promotional blurb actually means is "It's not against Canadian federal law for us to sell these as replacement parts for safety-certified vehicles". That is also why the Sylvania bulbs packed in boxes marked FOG LAMP USE ONLY (wink, wink) in the USA are packaged and sold as headlamp "upgrades" in Canada.

They're still unsafe. They're still noncompliant. They still expose whoever uses them to potentially severe liabilities in the event of a crash. It's just not federally illegal for them to be sold this way.
 
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