Irrational Recall of VW Headlights

https://leftlanenews.com/volkswagen/vw-recalls-660-000-cars--suvs-to-remedy-headlight-issue/

https://www.consumerreports.org/car...-over-vehicles-for-headlight-alignment-issue/

VW is recalling 160,000 vehicles because their headlamps can be aimed horizontally. They are missing a cap that prevents a person from accessing the adjustment screws and misaiming the lamps horizontally. NHTSA does not want anyone to tamper with horizontal aim.

But having vertical aim that is misaligned straight from the factory floor is OK with NHTSA (but not with IIHS).

As D. Stern writes over at drivingvisonnews:

In the mean time, we have the mind-bending situation that in the world's № 2 auto market, the presence of a demonstrably needed safety provision is considered an illegal "safety defect".

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Strange that they did not seem to file a petition for a decision of inconsequential noncompliance, such as what Bentley did when a similar situation arose: https://www.regulations.gov/docket?D=NHTSA-2009-0114

Bentley's petition was granted.

Vw may still be a little nervous about making to much noise after the whole desiel emission debacle

Is horizontal aim actually illegal in the US? I always thought it was something that wasn't required, but not against federal regs to have. Most BMWs have horizontal aim even in the US

All of my older vehicles, with "real" glass headlights, are adjustable for elevation and windage. Removing the horizontal adjustment sucks. So does removing individual adjustment for high and low beams.

If by "real" glass headlights you mean "sealed beams"; horizontal and vertical aim were typically both adjustable. Not sure I'd call the horizontal aim "windage", if the wind were severe enough to knock your photons to one side or another, you got bigger problems.

For dual-beam sealed beams, separate adjustment of the high beam should not be necessary (and would be impossible, anyway). Always aim on the low beam.

For multi-lamp sealed beams, the highs and lows are adjustable individually.

For composite lamps, the low and high beams are similarly linked such that aiming the low beam changes the aim of the high beam. Typically, the manufacturing tolerances are such that this isn't a problem. (Then there's the sealed beam form factor, replaceable light source HELLA 002395801, which has too high a vertical separation between the low and high beams, so when the low beam is aimed correctly the high beam is pointed up too high. No cure for that; just don't purchase that lamp. Get the DOT-spec HELLA 002395301 instead.)

Once again: Whenever the low and high beam aim is tied into the same function, aim the low beam.

terraphantm said:

Is horizontal aim actually illegal in the US?

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It's complicated:

S10.18.4 Horizontal adjustment-visually aimed headlamp. A visually/optically aimable headlamp that has a lower beam must not have a horizontal adjustment mechanism unless such mechanism meets the requirements of this standard for on vehicle aiming as specified in S10.18.8.
…

S10.18.8.1.2 Horizontal aim. The VHAD must include references and scales relative to the longitudinal axis of the vehicle necessary to assure correct horizontal aim for photometry and aiming purposes. An "0" mark must be used to indicate alignment of the headlamps relative to the longitudinal axis of the vehicle. In addition, an equal number of graduations from the "0" position representing equal angular changes in the axis relative to the vehicle axis must be provided.

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I always thought it was something that wasn't required, but not against federal regs to have.

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So long as it conforms to the Standard, it's allowed to have it.

Most BMWs have horizontal aim even in the US

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[Citation Needed]

terraphantm said:

Is horizontal aim actually illegal in the US?

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It is legal only if the headlamp is equipped with a "VHAD" (vehicle headlamp aim device). There are two kinds of VHAD for horizontal aim: the three bumps, properly called "aiming pads", on the front face of the lens that interface with a mechanical aimer -- this kind works only with headlamps where the lens moves with the reflector when the aim is adjusted -- or a calibrated scale and pointer that looks similar to ignition timing marks on an engine. Visual/optical horizontal aim is not allowed by Federal Motor Vehicle Safety Standard 108.

So automakers have two options: they can either provide horizontal aimability with a VHAD, which costs more, or they can provide no horizontal aimability, which costs less. Both of these options are equally as legal, so virtually all vehicles in the US do not have horizontal aimability.

Most BMWs have horizontal aim even in the US

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That is not correct.

Honestly, why does VW even bother to bring this up? The way I see it is that the NHTSA has stopped (publicly) caring about subjectively bigger issues, such as the proliferation of illegal HID/LED retrofit kits. And nobody had anything to say about this...and no, there are no bubble levels, mechanical aiming pads, or obstructions in the way of the horizontal adjustment screw on this US-spec Lexus IS350 lamp. The owners manual states to turn the horizontal adjuster in the same direction as the vertical adjuster, and to turn them an equal number of times. I guess two wrongs don't make a right!

Ls400 said:

there are no bubble levels, mechanical aiming pads, or obstructions in the way of the horizontal adjustment screw on this US-spec Lexus IS350 lamp. The owners manual states to turn the horizontal adjuster in the same direction as the vertical adjuster, and to turn them an equal number of times.

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I think it may be that both are vertical adjustments as with the LS430. The headlamp is large and heavy enough that it needs support at two points. If you turn only ONE it moves diagonally; one must turn both an equal number of turns so you don't move it towards one corner or another.

This really looks like a bad translation. Not as bad as, say, "Keep cap close usually" (radiator cap on a '76 Corolla DX wagon).

The '05 LS430 manual refers to "Vertical movement adjustment bolt 1" and "Vertical movement adjustment bolt 2"

LS430 manual pp. 503 & 504
1. Turn the vertical movement adjusting bolt 1 in either direction using a Phillips−head screwdriver. At this time, keep the turning direction and number of turns in mind.
2. Turn the vertical movement adjusting bolt 2 the same number of turns and in the same direction as step 1 using a Phillips−head screwdriver.

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Ls400 said:

Honestly, why does VW even bother to bring this up?

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Because they're required by law to report any noncompliance with regulations that apply to the vehicles they build. They tried just keeping quiet about a noncompliance not long ago. It didn't go well for them.

The way I see it is that the NHTSA has stopped (publicly) caring about subjectively bigger issues, such as the proliferation of illegal HID/LED retrofit kits.

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That's apples and...that's not even apples/oranges or apples/watermelons, it's apples/staplers.

[Your misunderstood stuff about Lexus aim adjustors skipped; Alaric did a good job explaining it to you]

I guess two wrongs don't make a right!

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What does this old favorite kindergarten playground scold have to do with the matter at hand?

Regarding two wrongs don't make a right: The government's apparent "don't care" attitude toward an arguably bigger safety issue doesn't justify VW ignoring rules regarding an arguably more minor safety issue (access to horizontal aiming screws)! That was what I was going for.

Thank you Alaric for the clarification!

This must be a rather new requirement, as the 99 accords have adjustment for both up and down and left/right.

Magio said:

This must be a rather new requirement, as the 99 accords have adjustment for both up and down and left/right.

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I see mention of the VHAD in a 1997 document; it may go further back than that.

Maybe so. I just installed a set of OEM 04 Odyssey headlights a few months back. These also had both horizontal and vertical aiming adjusters. My 17 accord coupe does not have a horizontal adjustment screw though.

Magio said:

Maybe so. I just installed a set of OEM 04 Odyssey headlights a few months back. These also had both horizontal and vertical aiming adjusters.

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Replacement parts probably have their adjusters uncapped because part of installing new headlamps (ostensibly after a collision, but for *any* reason) is correctly aiming the headlamps.

Magio said:

This must be a rather new requirement

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It took effect at the same time as visual/optical aiming became permitted. The regulatory negotiation took place in the mid '90s, and the first VOA headlamps were on a few 1998 models. That's now 21 years ago, which I don't really consider "rather new"...do you?

the 99 accords have adjustment for both up and down and left/right.

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The 1999 ('98-'02) Accord headlamp was designed and engineered before the advent of visual/optical aim. It is not a VOA headlamp—it has vertical and horizontal VHADs and vertical and horizontal aim adjusters.

Some relevant documents worth reading for education on the subject: start with this and google each of the FR citations it contains, especially this one (which is actually worth reading first) and this one (the VOA rule itself -- be sure to see section V, "V. Comments Not Relating to the NPRM").

Alaric Darconville said:

I think it may be that both are vertical adjustments as with the LS430. The headlamp is large and heavy enough that it needs support at two points.

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It seems to me that most headlamps are not heavy enough to warrant support at two points. From peering into various cars, I don't see many lamps that use two vertical adjustment screws. What is this extra weight from?

I read that reflectors can be made of various materials, from plastic to aluminum to magnesium. I also read a lot of anecdotes about certain BMWs ending up with burnt/damaged/cracked reflectors because the reflectors were apparently made of a not-very-durable plastic. Could the weight be indicative of more durable materials used?

Ls400 said:

It seems to me that most headlamps are not heavy enough to warrant support at two points. From peering into various cars, I don't see many lamps that use two vertical adjustment screws. What is this extra weight from?

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In the LS430, it could be from the servo that changes the horizontal aim of the low beam when turning. It's a large composite lamp with a separate high beam, and it holds the turn signal, front position light, front sidemarker and reflex reflector. Not to argue from authority, but I'm going to trust that Koito, NAL, or Stanley*​ knew what they were doing when they designed the lamp assembly and its aiming mechanism.

*​It's one of those three; the fog lamps on the LS430 are definitely Stanley but I'm not sure of the headlamp assembly

-Virgil- said:

That is not correct.

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I probably can't claim most since I have not personally worked on every single model BMW in existence, but every one that I have worked on does have horizontal aim capability. E38, E39, E46, E53, E83, E85, E60, E9x, F3x, F8x. Not all of those have VHAD capabilities. These aren't cases of euro headlamps retrofitted to US vehicles. And fully disassembling the headlamps (which is sometimes required on the older cars for things like replacing igniters) usually requires manipulating both the vertical and horizontal adjusters. I just double checked on the factory headlamps on my M3. They definitely have horizontal aim, are marked VOL, and do not have any sorted of VHAD.