Road legal LED headlights

2024 update!

There is an option for legal LED H4 bulbs in combination with special new reflectors. Read more…

In my full electric Volvo Amazon wagon all small things to reduce auxiliary power consumption help. In the end all the 12V components also consume from on the battery pack via the DC/DC converter. The less power consumption of components, the better. Therefore often all lighting is changed into LED giving you more light but less Amps.

LED headlight regulations

For running day light upgrading to LED is not trivial. On the one hand, because I think it is important to install good lamps that do not hinder other road users. On the other hand, this has to do with the legislation or ‘Regulation vehicles’. Article 4.2 states:

The sale or entry into service of a new component or separate technical unit intended to form part of a vehicle of the vehicle categories referred to in Article 4.1 shall be prohibited if that component or separate technical unit:

• a. does not comply with the requirements of the relevant EU directives and regulations listed in Annex IV or XI to Directive 2007/46/EC, Annex I to Regulation (EU) 167/2013, and Annexes II and V to VIII of Regulation (EU) 168/2013, or the relevant UNECE regulations; or
• b. does not bear the type-approval mark required by the relevant EU Directive or Regulation, or by the relevant UNECE Regulation.

It must therefore have an ECE type approval. The most beautiful and easiest way to upgrade to LED would be to use LED bulbs with H4 fitting. But take a look at a reputable manufacturer like Philips and their X-tremeUltinon LED [~H4]. But on that page it says:

Not for use on public roads in Europe
Important: In the EU and some other areas, LED lighting is reserved for interior and off-road use. LED headlights, fog lights and indicators are currently not ECE homologated and are not intended for use on public roads. When you use LED headlights, fog lights, and turn signals on public roads, you risk losing your driver’s license and your car insurance and getting fined. Philips LED lighting is not available in all countries.

After some further searching, it turned out that H4 LED lamps with ECE quality mark ‘by design’ were not possible. Most H4 LED lights that you can buy and in all cases in combination with original old reflectors are illegal for use on the road. The H4 lamps fall under the European regulation ECE-R20 while for LED lamps the ECE-R-112 applies.

Still MOT approval with the wrong set?

Surprisingly enough a car with such H4 LED bulbs can pass the Dutch MOT. This has to do with the fact that the MOT only tests for part of the underlying road traffic law. In the Netherlands, this goes relatively smoothly on the aspect of lighting. You only need to check for light image. As long as this is good, it is good in terms of MOT, but not yet legal. In Germany, for example, you can’t get away with it at all.

LED headlights with ECE approval

In 2024, I now have two options:

1. Special H4 LED bulbs in combination with approved reflectors
2. Complete 7-inch LED lamp units

Option two has the disadvantage that they don’t look as beautiful and authentic. So I have a preference for option 1. I’ve already bought it, but haven’t built it in or tested it yet, so practical experience will follow later.

1. Special H4 LED bulbs in combination with approved reflectors

The reason that H4 LED bulbs ‘by design’ were not possible is because the old and original Amazon reflectors where you put them were not tested and approved for LED. New possibilities have now been added in two generations.

Gen1 = H4 LED in combination with specific new fixture

Gen2 = H4 LED in combination with specific older fixtures

This is now mainly based on the H4 Night Breaker series from Osram, but there are several providers.

Osram has therefore had a new type approval done, which means that this option is now available. Read full ‘National Type Approval for specific technical parts‘ from their website.

Gen1 Osram Night Breaker H4-LED

This is Osram article 64193DWNB or EAN 4062172284691.

It only has a type approval in combination with reflector E11 0035. This number must therefore be in the glass, otherwise you cannot legally use this type of lamp in it.

By design, old reflectors don’t have this. After some searching, it turned out to be the Wipac H4 lamp unit (only for LHD).

Gen2 Osram Night Breaker H4-LED SM

The official name of the new generation is the Night Breaker LED Smart. This is Osram article 64193DWNBSM or EAN 4062172398138.

This is the version you will come across when you search in the total list of countries in the list for the Netherlands “Application list for cars, motorcycles and special vehicles” with specifically for cars, among others.

Then on page 25 the list starts with Volvo (including the 140) and on 26 is the Amazon. Here’s the big picture.

This new H4-LED Smart generation can therefore be used in combination with the E4 12 housing in the case of the Amazon and related devices.

And the good news: those just seem to be the older H4 halogen reflectors!

Skandix also has handy reading material for the LED bulbs “LED bulbs with ABE for classic Volvo“, although that is more focused on the Volvo 240.

Practical experience will follow! Ideally, I would like to place a comparison between the Osram Gen1 and Osram Smart each in the intended luminaires.

2. Complete 7-inch LED bulb units

Another option is complete 7-inch LED lamp units with ECE approval. For a relatively small amount on money you can buy lamps from China. However they often have only a E-approval, often E9. Even in case these markings are authentic, it is not sufficient. In the end I only found two complete light units with ECE approval. Note: these are for right hand traffic (often left hand drive cars).

JW Speaker 8700 Evolution 2 (ECE)

Details can be found on their website.

As far as I’m concerned, this lamp has two disadvantages: 1) I don’t like the looks. 2) The price, the cost about 400 euros each.

Truck Lite 27290C

Details can be found on their website.

This lamp is already more friendly priced and less ugly. After reading some reviews I decided to buy this lamp. Low beam draws 1.5 Amps per lamp and high beam 2.7 Amps. For comparison, H4 halogen draws 4.5 Amps and high beams 5 Amps.

LED headlights on Volvo Amazon

I ordered the lamps from Bowers in the UK. The construction feels solid and the lamp is indeed provided with the relevant marks.

Comparison H4 halogen vs LED headlights

It will take a while before the electric combi drives, so I have already put the lamps on our regular driving Amazon as a test.

Then put the lamps in. Even halfway in the dark, that was really a piece of cake. Apparently it was not a piece of cake because in the dark I had changed some wires so that the lamp flicker on high beam and on the left on low beam mode also the high beam was on. That has now been resolved.

I’m still not sure if I think they’re too modern. Immediately looked at the difference. The LED light is much whiter and therefore brighter and clearer.

Significantly more light than the H4 halogen lamps. (Sorry for the poor focus.)

However, the adjustment does not seem optimal to me yet. I’m under the impression that they can go a little higher. Although it may be that I was also on the bumpy path a bit different with the H4 halogen photo.

And below a short driving impression.

In the coming period I will leave the lamps on our red Amazon to see how I like it. In addition, next week to the MOT as a test for the light image.

Update MOT

In the meantime I have been to the MOT. Compliments from the judge, the lamps have a very good light image.

In terms of adjustment, they were indeed allowed to be a bit higher, mainly the left one. Now let’s see how it works in practice. The car is approved so MOT again until 2020.