Recall on Diode Dynamics retrofit LED bulbs

[Ls400]

I went through the first two pages trying to find a discussion on this topic already but I didn't see anything. I was a little surprised at not seeing some celebration at this good news!

Does anyone have any more information on this recall? Why the recall, all of a sudden? I'd expect even less aftermarket lighting enforcement action from the NHTSA (if less is even possible) during a lockdown!






Edited to add: https://www.nhtsa.gov/equipment-deta...555731#recalls

[-Virgil-]

I'm not for sure on how I feel about this. On one hand, hey, there's life at NHTSA after all! On the other hand...seriously, guys? There's tons of severely unsafe lighting garbage openly on sale on Amazon, ebay, etc, coming in by the bargeload from China without ever having passed within seeing distance of an engineer, and you don't do a thing about it even though it would be an easy and very lucrative slam-dunk? Instead you go stomp an American company making real engineering-based efforts to meet the demand with products that work about as safely as this kind of product can work at this point in time? Couldn't you shut down the gross polluters before you call out the infantry on the guy who littered? I agree littering is bad, too, but...hello, priorities...?

[SubLGT]

I don't see this as "stomping" on DD. It is more like a slap on the wrist. They were not fined. I predict vey few people will return their LEDs for halogen bulbs, and therefore the costs to DD will be relatively low.

I agree NHTSA should be going after the "big dogs" like Amazon, eBay, Autozone, O'Reilly Auto Parts, etc. Maybe NHTSA is intimidated by the big dogs.

Another agency, the EPA, has recently been going after smaller companies that sell kits to delete emissions controls on diesel pickups.
https://www.epa.gov/enforcement/clea...se-resolutions

I would like to see the federal government slap a 1000% tariff on these non-compliant LED bulbs coming in from China

[-Virgil-]

I don't see this as "stomping" on DD.

OK, spanking, swatting, slapping...

I predict vey few people will return their LEDs for halogen bulbs, and therefore the costs to DD will be relatively low.

Probably. But it still looks to me like it would incentivize DD to cut back on their R&D on this kind of thing, because NHTSA isn't likely to be as lenient next time. Meanwhile the completely unengineered garbage keeps pouring in.

I agree NHTSA should be going after the "big dogs" like Amazon, eBay, Autozone, O'Reilly Auto Parts, etc. Maybe NHTSA is intimidated by the big dogs.

Well, it's especially weird these days, with this administration. Specifically, President Trump loudly hates everything to do with Jeff Bezos (Washington Post, Amazon, etc). So it seems like his government would love to throw a bomb like this on Amazon. Amazon's too big to weasel out of it by declaring bankruptcy, it has detailed records for every single LED kit/HID kit they've ever sold, it has the logistics ways and means to do a huge recall and the cash to pay huge fines...

Another agency, the EPA, has recently been going after smaller companies that sell kits to delete emissions controls on diesel pickups

Good!

I would like to see the federal government slap a 1000% tariff on these non-compliant LED bulbs coming in from China

No, tariffs are for legitimate, legal products. What is supposed to happen with noncompliant regulated vehicle equipment is that it is supposed to get confiscated and destroyed and the would-be importer gets punished hard.

[Ls400]

Probably. But it still looks to me like it would incentivize DD to cut back on their R&D on this kind of thing

They do R&D? The SL1 looks to be a several-years old design, and I have seen no news about a "SL2."

Diode Dynamics, LLC (Diode) is recalling certain SL1 LED replacement headlamp bulbs, part numbers DD0215P, DD0216P, DD0217P, DD0218P, DD0219P, DD0323P and DD0340P. These bulbs exceed the luminous flux standards for replaceable light sources, may cause excessive glare or brightness to oncoming drivers. As such, these bulbs fail to comply with the requirements of Federal Motor Vehicle Safety Standard number 108, "Lamps, Reflective Devices, and Associated Equipment."

Is this saying that once DD tamps down the luminous fluxes of their LED retrofit bulbs to fall within the acceptable ranges for the corresponding halogen bulbs, they'll be good to go? I'm guessing no, because LED bulbs not only fail to meet the luminous flux requirements but a bunch of other requirements in 108. I'm also guessing that this was the "easiest" way to declare the DD LED bulbs illegal--measuring lumens is probably more straightforward and easier for the general public to understand than trying to determine of the gasket on a DD H11 LED bulb is up to spec? Finally, why did NHTSA even bother with quantifying lumens? Doesn't, say, the H11 bulb spec refer to the location and placement of the filament? These LED bulbs clearly don't have filaments--why go through the trouble of tripping the bulbs up on a technicality rather than just calling it how it is: there are no LED H11 bulbs recognized by 108?

Also, sort of a "wondering out loud" question--I note that NHTSA has logged 0 complaints wrt DD bulbs. I wonder what prompted NHTSA to stick some DD bulbs in an integrating sphere, then?

And where might one be able to find these lab reports? These lab reports should be publicly accessible, right? I seem to recall an online database of a bunch of results from lab tests commissioned by the NHTSA. I distinctly remember the fact that NHTSA had tested a 2005 NAL Camry headlamp with Calcoast-ITL and a bunch of other vehicles' lamps, too, and these results were all available in PDF format on a website whose URL I have forgotten...ETA: found it! But no DD SL1 test results in there. Perhaps they're slow to update? https://icsw.nhtsa.gov/cars/problems/comply/Index.cfm

[-Virgil-]

They do R&D?

They do.

The SL1 looks to be a several-years old design

I don't know...what about it looks several years old?

and I have seen no news about a "SL2."

Companies don't always use sequential numbers for new versions of products. I don't know for sure in this case, but we can't assume that "1" is for first generation, "2" for second generation, etc. The Toyota Corolla was introduced around 1965 or '66, and is now in its 12th generation, but it's still called Corolla, not "Corolla 12".

Is this saying that once DD tamps down the luminous fluxes of their LED retrofit bulbs to fall within the acceptable ranges for the corresponding halogen bulbs, they'll be good to go? I'm guessing no

I share your guess, but NHTSA works in mysterious ways.

I'm also guessing that this was the "easiest" way to declare the DD LED bulbs illegal--measuring lumens is probably more straightforward and easier for the general public to understand

Well, the easiest way is to look at the LED bulb, say "Huh, no filament. The spec says it has to have a filament". All done, no testing required. So again, NHTSA works in mysterious ways.

Finally, why did NHTSA even bother with quantifying lumens?

Maybe they're interested in keeping tabs on developments in LED bulbs. Maybe they had a testing budget for a certain time period and they had to "use it or lose it". Maybe there was some lawsuit or glare complaint or traffic ticket somewhere that caught the interest of someone important enough to tell NHTSA what to do.

there are no LED H11 bulbs recognized by 108

Well, technically there are no bulbs of any kind recognized by 108. The bulb specs are in Docket NHTSA-1998-3397.

And where might one be able to find these lab reports? These lab reports should be publicly accessible, right?

Good question. I don't know if they are or not, for this kind of recall. There are many different kinds of defect investigations, probably with different rules and protocols regarding publication of test data, etc.

I seem to recall an online database of a bunch of results from lab tests commissioned by the NHTSA.

That's a nice link full of interesting tests. One thing I noticed is the large amount of "Failed - no action taken" entries. Then you look at the test and sure enough, there are real noncompliances. And yet NHTSA knowingly ignores them, apparently. I guess I can understand if it's a picky little minor noncompliance (spec requires no more than 125 cd above 10U on low beam, tested lamps produce 127 cd, that kind of thing) but this many "Failed - no action taken" entries...? Really?

[SubLGT]

https://arstechnica.com/cars/2020/03...ermarket-leds/

Aftermarket LED replacement bulbs are illegal, but there's little enforcement at the federal level. We checked in with NHTSA and a spokesperson told us the following:

"There are currently no LED headlamp replaceable bulbs that meet federal safety standards. NHTSA is aware of illegal retrofit kits that are being sold to consumers and works closely with US Customs and Border Protection to prevent shipments containing these non-compliant headlamp bulbs from entering the United States. NHTSA continuously researches emerging technologies with the potential to enhance roadway safety."

[SubLGT]

https://www.novuslight.com/put-an-en...bs_N10635.html

... it is estimated that there are 60,000 illegal LED low-beam replacement bulbs sold online weekly and nearly 2 million [USA] consumers have installed these illegal products in their vehicles in the past year [2020]. (Written by Greg Bibbo, Director of aftermarket sales and marketing at Sylvania.)

[-Virgil-]

"dangerous and illegal LED low-beam replacement bulbs. Sadly, LED replacement bulbs are being sold illegally for both low-beam and high-beam applications in the U.S." Written by Greg Bibbo, Director of aftermarket sales and marketing at Sylvania

This Greg Bibbo, as director of Sylvania aftermarket sales and marketing, is directly responsible for Sylvania's aggressive pushing of EXACTLY THESE PRODUCTS he's pretending to be so upset about. He knows full and well that everybody ignores the BS warnings on his Sylvania Zevo LED bulbs. "For fog use only" -- it doesn't even say "for fog lamp use only". Nobody ever saw these at O'Reilly or AutoZone or Amazon and said "Oh, oops, even though it says 9006 in big bold type, it also says 'for fog use only' in little bitty type, so I guess I'd better buy something else instead, since I'm here for headlamps today". And it looks like those exact same bulbs are sold up in Canada with different packaging, explicitly promoted for headlamps. The failure of Canadian Motor Vehicle Safety Standard 108 to regulate the aftermarket, that somehow nullifies the technical reasons why these bulbs aren't safe? Not. And what's the deal with his deliberate and repeated emphasis on "low beam" bulbs? They're just as illegal, just as unsafe in the high beam.

As far as NHTSA's spokesperson as quoted in the Ars Technica article, how s/he can sit there and say NHTSA works closely with US Customs and Border Protection to prevent shipments containing these non-compliant headlamp bulbs from entering the United States with a (presumably) straight face and without Pinocchio-type nose effects is beyond me. If they were really preventing shipments from entering the country, the LED bulbs wouldn't be so easily and readily available.

Sheesh! What a steaming crock from both Sylvania and NHTSA.

[idleprocess]

As far as NHTSA's spokesperson as quoted in the Ars Technica article, how s/he can sit there and say NHTSA works closely with US Customs and Border Protection to prevent shipments containing these non-compliant headlamp bulbs from entering the United States with a (presumably) straight face and without Pinocchio-type nose effects is beyond me. If they were really preventing shipments from entering the country, the LED bulbs wouldn't be so easily and readily available.

I'm sure that I can grab a set of automotive HID or LED bulbs in the halogen base of my choice from the 'Bay, the 'Zon, or any other retailer today just as easily as one could score a 'HID kit' 20+ years ago. NHTSA and the rest of the alphabet soup might make some press seizing the occasional shipment, but judging by the number of vehicles driving around my region with headlamps showing all the signs of a HID kit - cooked reflector bowls, fogged lenses, throwing light everywhere but down the road - availability has not been much effected by their efforts. At least LED bulbs only commit the lattermost sin from my highly subjective perspective, and not as badly.

As far as I know, Diode Dynamics produces all of their product in the USA, so they're subject to direct regulation as opposed to import restrictions.

[Ls400]

They do.

I don't know...what about it looks several years old?

I recall the SL1 being introduced about 2 years ago, with a single isolux diagram showing how advantageous it would be to swap out the (then-current) stock F-150 bulbs for a DD bulb, and that was the extent of the hard data they presented. I should have clarified: I wasn't aware of any substantive R&D efforts. The singular diagram was nice, but I don't believe that they've released more data on DD LEDs in other vehicles. Do you have more information on how the DD would perform outside the F-150? Or actually, do you have any more information about the DD in the F-150--like, does the increase in 5 lux illumination distance come with a healthy and illegal dose of glare?

That's a nice link full of interesting tests. One thing I noticed is the large amount of "Failed - no action taken" entries. Then you look at the test and sure enough, there are real noncompliances. And yet NHTSA knowingly ignores them, apparently. I guess I can understand if it's a picky little minor noncompliance (spec requires no more than 125 cd above 10U on low beam, tested lamps produce 127 cd, that kind of thing) but this many "Failed - no action taken" entries...? Really?

It's been a while since I read through each of the (lengthy) reports, so I'm curious: what vehicles did you find real/substantive noncompliances on, but NHTSA failed to take action on?

Good question. I don't know if they are or not, for this kind of recall. There are many different kinds of defect investigations, probably with different rules and protocols regarding publication of test data, etc.

Well, if our tax dollars are paying for these tests, then I wanna see the results !

This seems like the kind of thing I should email the NHTSA about, and should that fail, file a FOIA for.

Finally, cynical me says that this "targeting" of Diode Dynamics is motivated by its "mere" few million dollars in revenue from selling 27,890 $120 USA-made LED bulbs, which is eating into the business of the overseas suppliers and, of course, Sylvania's business .

[-Virgil-]

I recall the SL1 being introduced about 2 years ago

OK, and how do you figure that necessarily means there's no R&D going on?

I wasn't aware of any substantive R&D efforts. The singular diagram was nice, but I don't believe that they've released more data on DD LEDs in other vehicles.

Wait a sec, let's not mix our apples and our oranges. Whether or not a company is doing substantive R&D is a completely separate question from whether or not a company releases/publishes any particular type or amount of data.

Do you have more information on how the DD would perform outside the F-150?

No, I don't work for Diode Dynamics and don't have any other entree to this kind of data.

It's been a while since I read through each of the (lengthy) reports, so I'm curious: what vehicles did you find real/substantive noncompliances on, but NHTSA failed to take action on?

I don't mean to be unreasonable or churlish, but this is like asking me to google something for you. I mean, if I could see that info with a couple of mouse-clicks...so can you! :-)

Well, if our tax dollars are paying for these tests, then I wanna see the results ! This seems like the kind of thing I should email the NHTSA about, and should that fail, file a FOIA for.

Let us know how it goes!

[SubLGT]

https://www.nhtsa.gov/recalls?nhtsaId=21E002000

Ningbo shuwu Import & Export Co.,ltd (Ningbo) is recalling certain aftermarket Hikari headlight bulbs, LED-V39-R3 and RS-R models (in configurations H1, H4, H7, H11, H13, 9004, 9005, 9006, 9007, 9012) sold through Amazon.com. These bulbs may create excessive glare or brightness for oncoming traffic. As such, these bulbs fail to comply with the requirements of Federal Motor Vehicle Safety Standard number 108, "Lamps, Reflective Devices, and Associated Equipment."

Remedy

Ningbo will notify distributors, and owners, and will replace the bulb with halogen bulbs, free of charge. The recall is expected to begin February 1, 2021. Owners may contact Ningbo customer service at 1-812-250-8051 or by recall@hikari-led.net.

[-Virgil-]

Ningbo Free Trade Zone Shuwu Import and Export Co., Ltd. Well, that certainly sounds like a reputable, legitimate maker of vehicle safety components like headlight bulbs! I'm sure they have dozens (if not hundreds or thousands) of real engineers, with real engineering degrees from real universities. And all the right facilities and equipment, too.

[XeRay]

Ningbo shuwu Import & Export Co.,ltd (Ningbo City, Zhejiang province, China) is recalling certain aftermarket Hikari headlight bulbs: www.hikariled.com (note: a slightly different site for their recall) recall@hikari-led.net
Their website claim as Japanese source etc. but actually China. Ningbo is a city in China. https://en.wikipedia.org/wiki/Ningbo
Just Like "Morimoto" sounds Japanese but all their stuff is from China, "Hikari" is the same trick.

[-Virgil-]

Their website claim as Japanese source

Their website also claims "the eyes of mega tron." Honestly, I don't see how NHTSA can possibly enforce a recall. Puny safety regulations and optical physics are no match for the eyes of mega tron.

They also have this funny joke on their website:

DISCLAIMER FOR UNITED STATES PURCHASERS. Automotive LED bulbs should be used only for supplementary lighting purposes, such as fog lights, and you should check with the laws of your own state before doing so. The seller is not certifying as DOT/FMVSS 117 compliant, is not selling, and is not marketing LED bulbs for headlamp high-beam, low-beam usage.

Well, I'm sure glad they told me this disclaimer, or else I might have been confused and thought their products meet the requirements of FMVSS 117 (retreaded pneumatic tires).

[XeRay]

They also have this funny joke on their website:
Well, I'm sure glad they told me this disclaimer, or else I might have been confused and thought their products meet the requirements of FMVSS 117 (retreaded pneumatic tires).

Ha ha, I did not catch that, I did notice 117 not 108 but did not bother to look it up, so funny.

There are always telltale signs of a scam, if you look a little deeper.

[-Virgil-]

I haven't checked all the pages on their web site yet, so I haven't found the page where they say they are the Nigerian Crown Prince who wishes to give me the sum thirty million US dolares (30,000,000$) and due to the new security measure in the International Money Clearing Hoose it is necessary that I will am giving my the bank account number as showing of the good faiths.