International Newsmaker Q&A: Daniel Stern

Jan. 1, 2020
Consultant Daniel Stern is general editor at, an industry journal aimed at the automotive lighting segment.
Consultant Daniel Stern is general editor at, an industry journal aimed at the automotive lighting segment. He additionally participates in the research and development of U.S., Canadian and international vehicle lighting technical standards and rules.

Stern has written state and provincial vehicle lighting codes and inspection protocols, and has been a product development manager for aftermarket vehicle lights. He owns five unusual cars, and in his spare time he collects technically and historically significant car lights. His home base is in Vancouver, B.C., Canada. He can be reached at [email protected].

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He recently answered a series of questions about LED (Light Emitting Diode) systems:

More and more vehicles have LED lighting as original equipment. What does this mean for the aftermarket?

First and foremost, it means all sectors of the aftermarket have to be extra careful not to expose themselves to expensive liability by manufacturing, importing, distributing, selling or installing lighting equipment that doesn’t meet federal safety standards.

Whenever a highly visible new technology starts appearing on new cars – and nothing’s more visible than lighting — naturally people want to join the trend and make their cars look new. They hear about the theoretical benefits of the new technology, but there’s not much talk of the limitations, so everyone thinks they can add it to their car and get an upgrade; there’s a strong demand for retrofits. We saw it with HID kits to convert halogen headlamps to Xenon, and we’re seeing it with LED bulbs and LED replacement light units.

There’s a lot of easy money to be made. But it’s risky business; the problem with all the LED bulbs is the same as the problem with all the HID kits — they’re illegal and dangerous because there’s no way for them to meet the performance requirements specified in Federal (and Canadian) Motor Vehicle Safety Standard 108.

But that’s mostly a problem with the cheap stuff, not the good stuff, right?

It’s not a matter of picking out the good ones and rejecting the bad ones; the problem with an LED bulb or an HID kit is with the concept itself. There are detailed, very specific performance requirements for every vehicle exterior lighting function. The amounts of light have to be within the allowable range, and the light has to be spread correctly throughout the right range of angles so the brake light (or turn signal, tail light, headlamp, etc.) can convey its message quickly, accurately and without confusion, day or night, rain or shine, to other drivers no matter whether they’re up high in a semi tractor, down low in a sports car, two lanes over merging onto the highway, sitting in a side street waiting to join into traffic, etc. It’s not a simple job to make a light that does the job safely and effectively; it takes more than just a light source and some colored plastic.

Each lighting device is engineered and designed to use only one kind of light source. Putting the wrong kind of light source in – an HID kit in place of a halogen bulb, or an LED bulb in place of a filament bulb, for example – spoils the safety performance of the lamp. You may think a retrofitted lamp looks OK, looks bright enough, but the human eye is a lousy judge of its own performance, which is why the safety standards are based on objective measurements made on accurate test equipment, not on subjective impressions made by an observer peering at a light. Wrong light sources like HID kits and LED bulbs always fail badly when they’re tested.

But what if that doesn’t affect me because we don’t have vehicle inspections here?

Maybe not, but noncompliant lighting equipment is federally illegal. Some of it’s illegal because the equipment itself doesn’t comply with the regulations – that’s mostly headlamps, taillamps, any exterior lighting device. Some of it’s illegal because it spoils the safety compliance of the vehicle when you install it – that’s what’s wrong with HID kits and LED bulbs. Manufacturing, importing, distributing, selling or installing noncompliant lights exposes you to huge costs and liability risks. Shipments of illegal car lighting equipment are routinely seized and destroyed, and you don’t get your money back.

If you’re caught selling illegal lights, you can be spanked with heavy civil penalties – millions of dollars – and forced to recall all of the non-complying equipment you sold. If your illegal lighting is found to have contributed to a crash, you can be sued and lose your shirt (and everything else you own) in court. It seems like everyone’s doing it, but the DOT is stepping up enforcement and it’s just not worth the risk. And contrary to popular myth, labeling or advertising non-complying vehicle equipment as “off-road use only” does not exempt or protect you, because the law says a device must comply with the rules if it is physically capable of being installed in an on-road vehicle.

Keep in mind there’s no such thing as “DOT approval” or “SAE approval” – DOT and SAE don’t approve vehicle components; anyone who tries to get you onboard with their “DOT approved” lights is either telling lies they hope you won’t catch, or doesn’t know enough about the rules these products must meet to be qualified to make and distribute them. Instead of approval, we have what's called “self-certification:” The maker or importer of a piece of vehicle equipment is responsible for testing and certifying that the part meets the regulations. There’s no prescribed test, it’s left up to the maker. So you have to use discretion, common sense and good judgment. Anybody can say their lights are legal – anybody can stamp “DOT” on a lens. You have to do your homework to make sure they’re really OK.

The same goes for halogen headlight bulb upgrades. Any bulb with higher-than-standard wattage is illegal and dangerous; you can cook the car’s wiring and burn out the expensive body computer, melt sockets and headlamp reflectors, etc. Even standard-wattage bulbs can be a problem if they have too much color tint to their glass. Any amount of tint reduces the amount of usable light reaching the roadway, but some consumers want a "whiter" look to their halogen lights. Your best bet is to stock bulbs from reliable makers – the GE Night Hawk Platinum and Philips Xtreme Power bulbs are cutting-edge state-of-the-art in terms of safely and legally amping up headlamp performance and giving a blue glint, and Sylvania’s Silver Star bulbs are widely liked for their whiter-light performance.

My customers want to upgrade their lights. What can I sell them?

Even if you wisely refuse to sell the illegal and dangerous stuff, there’s still a lot of legitimate upgrade lighting equipment you can offer. It’s definitely not the case that only OE-type lighting is permitted. Any lighting device that meets the legal requirements is legal to make, import, sell and install. And there are enough of those products that it’s not hard to build up a solid, profitable lighting upgrade product line. Look for products made by legitimate, reputable companies.

Most of the companies putting out safe, legal, effective aftermarket lights are also heavily involved in OE lighting production, so you’re on very solid ground handling those brands – Hella, for example, has a huge, very good aftermarket lighting product line including LED taillamps for some of the most popular vehicles on American roads. Then there are companies who may not have much presence in OE passenger car lighting, but who do a lot with OE and replacement lights for trucks and commercial vehicles. JW Speaker has a terrific lineup of LED fog lamps and LED headlamps, and so does Truck-Lite. Those are both American companies making high-quality products with unquestionable legality and safety performance.

The options in good upgrade lights are pretty slim right now for passenger cars. There’s a healthy lighting aftermarket for German cars, mostly put out by the OE makers (Valeo, Bosch-AL, Hella, ZKW) and a few aftermarket suppliers like, because Germans are enthusiastic about car lights.

The OEMs tend to try out their new technology by releasing aftermarket retrofit kits for existing vehicles. And they also release aftermarket update kits, for example, to put headlights on a VW Golf 5 that look like the ones on a Golf 6. German auto magazines and their equivalent of AAA routinely publish big comparisons of various cars’ headlight performance, and there are annual events where lighting manufacturers send trucks out to rove the streets and parking lots, offering free headlight aim adjustment and replacement of burned-out bulbs to motorists.

We just don’t have that kind of thing here – it’s almost impossible to get a truly accurate, precise, correct headlamp aim adjustment in North America, even if you’re prepared to go in a shop and pay for it. Shining the lights on a wall just isn’t good enough – not by a long shot. An optical beamsetter is needed to do the job right. There are a bunch of companies offering them, and they quickly pay their keep. Since headlamp aim is by far the number one factor influencing a driver’s ability to see well at night, the shop that can offer fast, efficient, correct headlight and fog lamp aim jobs will have a big marketing advantage.

The other thing that paves the way for a strong aftermarket lighting scene for European cars is that there’s a clear, uniformly applied system of type approval that applies equally to OE and aftermarket parts in Europe. The regulations are clearly written and available for free download in multiple languages. So we’re at a disadvantage in the North American market because so many of the technical requirements are in documents you have to buy. So there’s not as much of a bustling lighting aftermarket scene for American, Japanese and Korean cars. That means there’s a wide-open market just waiting to be served by whoever wants to step up and do it with safe, high-quality, legally sound upgrade lights.

Much of the aftermarket lighting products at present are being produced by sketchy companies who claim their lights are DOT compliant, even when they’re not. A lot of the noncompliant lights are coming in from China and other countries where safety regulations aren’t taken seriously, and it’s more of a “whatever you can get away with” situation. Be skeptical and picky.

Make sure any car light you import, distribute, sell or install performs all the functions produced by the original light, and in the same colors. Front sidemarkers have to produce and reflect amber light; rears have to be red, for example. A lot of aftermarket taillights lack the required side-facing red reflector. That’s illegal, and so are “clear corners” that eliminate the front amber side reflector. And even aftermarket devices that have all the original functions may still not be legal because they may not meet the less visible requirements for durability, waterproofing, etc.

The picture is brighter for lots of trucks, vans and trailers still running the old sealed or bulb-replaceable incandescent brake, turn signal and marker lights, and sealed-beam headlamps. It’s win-win-win when owners and operators replace those devices with same-size, same-shape LED lights made by reputable makers like Grote, Peterson, Truck-Lite or JW Speaker. The reliable makers have scads of options. Spend some time in their catalogs and you’ll see. And the range of options can only get larger.

Osram Opto Semiconductors, the LED branch of the Osram parent company of Osram-Sylvania, has a nifty line of JOULE LED car lights that now includes a very high-performing single-LED fog lamp. It’s certified and type approved to the latest international European and U.S./Canadian regulations, very cutting edge in performance, and it uses almost no power. So far it has been commercialized only as an accessory for BMW motorcycles, but since the fog lamp unit itself is modular, it’s just waiting for an enterprising aftermarket outfit to package it up with appropriate brackets for aftermarket installation on popular passenger cars, SUVs and trucks.

Philips and Hella have a growing lineup of LED daytime running light kits in different sizes and shapes for aftermarket retrofitment. They’re approved and certified, take very little power to run and are easy to install. Some of them are dual-mode, bright for the daytime running light function and dim for the nighttime parking light function. They’re great, another big win for everyone: the consumer gets a big, very visible style improvement with the sharp, bright-white, up-to-date look of white LEDs on the front of the car, together with a big safety improvement from having the latest type of daytime running lights. And the sales win is obvious for the distributor, retailer and installer!

About the Author

James Guyette

James E. Guyette is a long-time contributing editor to Aftermarket Business World, ABRN and Motor Age magazines.

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