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SUBMITTER: GTB WG LS
Document No. LS-1101
Date: 2015-09-11
Page 1 of 20
Originating document number(s) in case of a WG or TF submission LS-1050
Supersedes document numbers
LS-1102
LS-1098
LS-1083 LS-1087
CE-5134
CE-5114
GTB-119-10
GTB-119-36
Reference documents(s) CE-4792
Version of the relevant Regulation(s) the proposal is based on R128 draft
Suppl. 4
Percentage of WG experts who participated in the decision to adopt the
proposal xx %
Work item numbers 78, 91, 92, 93
TITLE LED retrofit feasibility study (2012-2015) - outcome and revised proposal
REQUESTED ACTION: Submission to 76th WG LS session for final check and consensus
CE Fast-track approval for submission as informal document to GRE74
Deadline for replies: 2015-09-25
NOTE This document is the outcome of an intermediate teleconference WGLS 76 on LED retrofit.
Consideration of additional IEC test performance requirements is in the WGLS agenda.
DISTRIBUTION: WG/TF LS experts
GTB Committee of Experts
GTB Technical Steering Committee
GTB Head-delegates
GTB Secretary
GTB Chairman
GRE
Others
Transmitted by the expert from GTB
Informal document GRE-74-xx
(74th GRE, 20-23 October 2015,
agenda item 4(c))
Date: 2015-09-11 Submitted by: WGLS chair
Proposal to introduce requirements for LED retrofit light sources and LED retrofit light source categories C5W, PY21W and R5W into Regulation No. 128
(Based upon Regulation No. 128 up to and including draft Supplement 4.)
I. Proposal
Amend paragraph 2.2.2., to read:
“2.2.2. Every application for approval shall be accompanied (see also
paragraph 2.4.2.) by:
2.2.2.1. Drawings in triplicate, sufficiently detailed to permit identification of the
type;
2.2.2.2. A brief technical description including the correlated colour temperature
of the light emitted in case of an LED retrofit light source emitting white
light;
2.2.2.3. Five samples of each colour which has been applied for;
2.2.2.4. In the case of LED retrofit light sources, instructions for fitting of these
LED retrofit light sources including a list of vehicle models and lighting
functions in which the use of these LED retrofit light sources is suitable;
2.2.2.5. The report according to paragraph 8.3.2.2. of this Regulation;”
Insert new paragraph 2.3.1.5., to read:
“2.3.1. LED light sources submitted for approval shall bear on the cap:
…..
…. the approval mark;
2.3.1.5. The markings as indicated in paragraph 2.3.3, if applicable. “
Insert a new paragraph 2.3.3. and renumber the old paragraph 2.3.3 into 2.3.4, to read:
“2.3.3. LED retrofit light sources of categories listed in the table for group 4 in
annex 1 shall be marked “LED” and with the symbol as indicated in
paragraph 8.3.3.3. The mark “LED” shall be placed after the category
designation separated by a single space, e.g. “PY21W LED”.
2.3.4. Inscriptions other than those covered by paragraphs 2.3.1. and 2.4.4. may be
affixed, on the condition that they do not adversely affect the luminous
characteristics.”
Insert a new paragraph 3.1.14, to read:
“3.1.14. LED retrofit light source: a LED light source which is a replacement
part for a filament light source of the same category.
Insert a new paragraph 8, to read:
Date: 2015-09-11 Submitted by: WGLS chair
3
“8. Retrofit provisions
8.1. No LED retrofit light source shall be used for type approval purposes of
lamp units.
8.2. No LED retrofit light source shall be used for conformity of production
control purposes of lamp units.
8.3. Instructions for fitting of LED retrofit light sources
8.3.1. Instructions for correct fitting of LED retrofit light sources shall be
given by the LED retrofit light source manufacturer.
8.3.2. Instructions for fitting of an LED retrofit light source shall include a list
of vehicle models and lighting functions in which the use of this LED
retrofit light source is suitable.
8.3.2.1. A lighting function in a vehicle model shall not be included in this list if:
(a) The LED retrofit light source is emitting white light of a correlated
colour temperature* exceeding 3000K and the lighting function is of
another colour than white;
* CIE S 017/E:2011: ILV: International Lighting Vocabulary, or eILV; term 17-
258
(b) The light source(s) producing the lighting function is operated by a
variable luminous intensity control.
8.3.2.2. The applicant shall annex to the type approval documentation a report,
acceptable to the Authority responsible for type approval, demonstrating
that in the listed vehicle models and lighting functions:
(a) the electrical current profile of the LED retrofit light source does
not interfere with the vehicle’s failure-detection equipment and/or
on-board diagnostic systems, if any;
(b) in the case that the LED retrofit light source is located in a
headlamp body above a light source of a rated wattage of 50W or
more and direct air flow is possible from this light source up to the
LED retrofit light source, the hot luminous flux value of the LED
retrofit light source shall not be less than 70% of its objective
luminous flux value at 13.5V DC.
This hot luminous flux value shall be measured determined after 30
minutes of operation of the LED retrofit light source at 13.5V DC in
still air of a temperature that is equal to the ambient temperature of
the LED retrofit light source installed in the headlamp, when this
headlamp is in still air at a ambient temperature of (23 ± 5) °C and
with both light sources activated.
In the case where doubt exists in respect to the accuracy of the report,
the Authority responsible for type approval may request verification of
the report by testing on the vehicle by a Technical Service.
Formatted: Indent: Left: 1.58"
Date: 2015-09-11 Submitted by: WGLS chair
4
8.3.3. Each LED retrofit light source shall be accompanied by instructions for
fitting of LED retrofit light sources in the language of the country where
the light source is sold with the following content:
8.3.3.1. At the point of sale, clearly visible, without removing the packaging:
Important
This LED retrofit light source is only suitable for fitment in the
following vehicle models and for the functions stated. If incorrectly
used this LED retrofit light source may cause a fault in your vehicles
electrical system and may affect the vehicle warranty.
VEHICLE LIGHTING FUNCTION(S)
(Unique Model identification) (Lighting function according to R48)
8.3.3.2. On the packaging: the address to which the customer can write to obtain
further information
8.3.3.3. On the packaging, reference should be made to the fitting instructions
using the symbol below:
8.4. The LED retrofit light source shall comply with the technical
requirements to an electrical/electronic sub-assembly (ESA) as specified
by Regulation No. 10 and its series of amendments in force at the time of
application for type approval.”
Annex 1,
The List of categories of LED light sources and their sheet numbers, amend to read:
“List of categories of LED light sources, grouped and their sheet numbers
“RESERVED”
Group 1
Without general restrictions:
Category
Sheet number(s)
Date: 2015-09-11 Submitted by: WGLS chair
5
Group 2
Only for use in signalling lamps, cornering lamps, reversing lamps and rear registration
plate lamps:
Category
Sheet number(s)
LR1 LR1/1 to 5
LW2 LW2/1 to 5
LR3A LR3/1 to 5
LR3B LR3/1 to 5
LR4A LR4/1 to 5
LR4B LR4/1 to 5
Group 3
RESERVED
Group 4
LED retrofit light source categories
For replacement of light sources of the same category but according to Regulation No.37
Category Sheet number(s)
C5W C5W_LED/1 to 4
PY21W PY21W_LED/1 to 4
R5W R5W_LED/1 to 4
List of sheets for LED light sources and their sequence in this annex:
Sheet number(s)
LR1/1 to 5
LW2/1 to 5
LR3/1 to 5
LR4/1 to 5
LED retrofit light sources only
Sheet number(s)
C5W_LED/1 to 4
PY21W_LED/1 to 4
Date: 2015-09-11 Submitted by: WGLS chair
6
Sheet number(s)
R5W_LED/1 to 4
“
After sheet LR4/5, add new sheets C5W_LED/1 to 4, PY21W_LED/1 to 4 and R5W_LED/1 to 4, to read
(see following pages; one page per sheet):
Date: 2015-09-11 Submitted by: WGLS chair
7
Category C5W Sheet C5W/1_LED
The drawings are intended only to illustrate the essential dimensions (in mm) of the LED
light source.
Figure 1
main drawing
Tab le 1
Essential electrical and photometrical characteristics of the LED light source
Dimensions in mm
LED light sources of normal production
min. nom. max.
b 1/ 34.0 35.0 36.0
e 2/ 0.0
f 2/ 9.0
Cap SV8.5 in accordance with IEC Publication 60061 (sheet 7004-81-4)
Electrical 5/ and photometric characteristics
Rated values Volts 12
Watts 2
Test voltage Volts 13.5
Objective values
Watts 2 max.
Luminous flux 3/
(in lm at 13.5 V DC) 45 20 % 4/
Luminous flux 3/
(in lm at 9 V DC) 9 min.
1/ This dimension corresponds to a distance between two apertures of 3.5 mm diameter each bearing against
one of the caps. 2/ to be checked by a “box system”, see Figure 2 3/ The light emitted from LED light source shall be white 4/ The value measured at elevated ambient air temperature of 80C shall be at least 70% of this value. 5/ In case of LED light source failure 6/ the electrical current draw, when operated between 12 V and 14 V, shall
be less than 50 mA 6/ Short-circuit between the terminals of the LED retrofit light source is not included
reference plane
b/2 b/2 f
Date: 2015-09-11 Submitted by: WGLS chair
8
Category C5W Sheet C5W/2_LED
Screen projection requirements
The following test is intended to define the requirements for the apparent light emitting area
of the LED light source and to determine whether the light emitting area is correctly
positioned relative to the reference axis and reference plane in order to check compliance
with the requirements.
The position of the light emitting area is checked by means of a box system defined in
Figure 2, which shows the projections when viewing along the direction = 0° (top view)
and = 90° (front view) and =180° (bottom view) and = 270° (rear view) in the plane
C0 (C, as defined in Figure 3).
The proportion of the total luminous flux emitted into the viewing direction from the
area(s)
- A, B and C together shall be 70 per cent or more
- B shall be 20 per cent or more
- A and C shall each be 15 per cent or more
Figure 2
Box definition of the light emitting area (front, rear, top, bottom view)
Table 2
Dimensions of the box system in figure 2 (Front, rear, top and bottom view)
Reference a h1, h3 h2
Dimension (mm) 2.5 6 2
A B C
Reference plane
Reference axis
h1 h2 h3
a
a
h2
Date: 2015-09-11 Submitted by: WGLS chair
9
Category C5W Sheet C5W/3_LED
Normalized luminous intensity distribution
The following test is intended to determine the normalized luminous intensity distribution
of the light source in the C-planes as described in figure 3. The intersection of the reference
axis and the reference plane is used as the coordinate system origin.
The light source is mounted on a flat plate with the corresponding holder features. The plate
is fixed to the goniometer table by a bracket, so that the reference axis of the light source
lines up with one of the rotating axis of the goniometer. The corresponding measurement
set-up is described in figure 3.
Luminous intensity data is recorded with a standard photo-goniometer. The measurement
distance should be chosen appropriately in order to make sure that the detector is located in
the far field of the light distribution.
The measurements shall be performed in C-planes, where C0 shall be the reference plane of
the light source. The C-planes to be measured shall be C0, C30 and C330. The test points for
each plane and multiple polar angles are specified in Table 3.
The measured luminous intensity values, normalised to the measured luminous flux of the
individual light source under test, shall be converted to normalised luminous intensity
values of a 1000 lm light source. These data shall comply with the tolerance band as
defined in Table 3.
Figure 3
Setup to measure the luminous intensity distribution
(Definition of C-Planes and angle )
C-planes: see CIE publication 70-1987, "The measurement of absolute intensity
distributions".
C0 C330 C30
Reference axis
reference plane
Date: 2015-09-11 Submitted by: WGLS chair
10
Category C5W Sheet C5W/4_LED
Table 3
Test point values of normalized intensity in the planes C0, C30, C330
intensity
in cd /1000 lm
Min Max
-175° 60 140
-150° 60 140
-125° 60 140
-100° 60 140
-75° 60 140
-50° 60 140
-25° 60 140
0° 60 140
25° 60 140
50° 60 140
75° 60 140
100° 60 140
125° 60 140
150° 60 140
175° 60 140
The luminous intensity distribution as described in Table 3 shall be substantially uniform,
i.e. in between two adjacent grid points the relative luminous intensity requirement is
calculated by linear interpolation using the two adjacent grid points.
Date: 2015-09-11 Submitted by: WGLS chair
11
Category PY21W Sheet PY21W_LED/1
The drawings are intended only to illustrate the essential dimensions (in mm) of the LED
light source
Figure 1
Main drawing
Table 1
Essential electrical and photometric characteristics of LED light sources
Dimensions in mm LED light sources of normal production
min. nom. max.
e 31.8 2/
h 9.0 2/
75° 90° 105°
Cap BAU15s in accordance with IEC Publication 60061 (sheet 7004-19-2)
Electrical5/ and photometric characteristics
Rated values
Volts 12 24
Watts 7 3/
Test voltage Volts 13.5 28.0
Objective values
Watts 9 max. 3/ 10 max. 3/
Luminous flux3/, 4/ (in lm at 13.5 V DC)
280 20 %
Luminous flux3/ (in lm at 9 V DC)
56 min.
1/ The light emitted from the LED light source shall be amber 2/ To be checked by means of a "Box-System"; sheet PY21W_LED/2 3/ Operated in flashing mode for 30 minutes (frequency = 1.5 Hz, duty cycle 50 per cent ON, 50 per cent OFF)
and measured in the ON-state of flashing mode after 30 minutes of operation 4/ The value measured at elevated ambient temperature of 80C shall be at least 65% of this value. 5/ In case of LED light source failure 6/ the electrical current draw, when operated between 12 V and 14 V, shall
be less than 50 mA 6/ Short-circuit between the terminals of the LED retrofit light source is not included
Date: 2015-09-11 Submitted by: WGLS chair
12
Category PY21W Sheet PY21W_LED/2
Screen projection requirements
The following test is intended to define the requirements for the apparent light emitting area of the
LED light source and to determine whether the light emitting area is correctly positioned relative
to the reference axis and reference plane in order to check compliance with the requirements.
The position of the light emitting area is checked by means of a box system defined in Figure 2,
which shows the projections when viewing along direction = 0° (top view) and = ± 90° (front
and rear view) in the plane C0 (C, as defined in Figure 3).
The proportion of the total luminous flux emitted into the viewing direction from the area(s)
- A, B and C together shall be 80 per cent or more
- B shall be 25 per cent or more
- A and C shall each be 15 per cent or more.
Figure 2
Box definition of the light emitting area with dimensions as specified in table 2
The lateral position of the light emitting area needs to be centred in the plane containing the
reference axis and being perpendicular to the plane containing the reference axis and the reference
pin.
Table 2
Dimensions of the box system in figure 2
Reference a (front view) b(top view) h k
Dimension 3.5 3.0 9.0 1.0
top view
front view
Date: 2015-09-11 Submitted by: WGLS chair
13
Category PY21W Sheet PY21W_LED/3
Normalized luminous intensity distribution
The following test is intended to determine the normalized luminous intensity distribution of the
light source in the planes containing the reference axis as described in figure 3. The intersection of
the reference axis and the edge of the box is used as the coordinate system origin.
The light source is mounted on a flat plate with the corresponding mounting lug features. The
plate is mounted to the goniometer table by a bracket, so that the reference axis of the light source
lines up with one of the rotating axis of the goniometer.
Luminous intensity data is recorded with a standard photo-goniometer. The measurement distance
should be chosen appropriately, to make sure that the detector is located in the far field of the light
distribution.
Figure 3
Setup to measure the luminous intensity distribution
(Definition of C-Planes and angle )
The measurements shall be performed in C-planes, which contain the reference axis of the light
source. The C-planes shall be C0, C30 and C330 . The test points for each plane and multiple polar
angles are specified in Table 3.
The measured luminous intensity values, normalised to the measured luminous flux of the
individual light source under test, shall be converted to normalised luminous intensity values of a
1000 lm light source. These data shall comply with the tolerance band as defined in Table 3.
C-planes: see CIE publication 70-1987: "The measurement of absolute luminous intensity
distributions".
Date: 2015-09-11 Submitted by: WGLS chair
14
Category PY21W Sheet PY21W_LED/4
Table 3
Test point values of normalized intensity in the planes C0, C30, C330
Minimum intensity
in cd /1000 lm
Maximum intensity
in cd/1000 lm
-150° 60 140
-125° 60 140
-100° 60 140
-75° 60 140
-50° 60 140
-25° 60 140
0° 60 140
25° 60 140
50° 60 140
75° 60 140
100° 60 140
125° 60 140
150° 60 140
The luminous intensity distribution as described in table 3 shall be “substantially uniform”,
i.e. in between two adjacent grid points the relative luminous intensity requirement is
calculated by linear interpolation using the two adjacent grid points.
Date: 2015-09-11 Submitted by: WGLS chair
15
Category R5W Sheet R5W/1_LED
The drawings are intended only to illustrate the essential dimensions (in mm) of the LED
light source
Fig 1
Main drawing
Table 1
Essential electrical and photometric characteristics of the LED light source
Dimensions in mm
LED light sources of normal production
min. nom. max.
e 2/ 19.0
f 2/ 4.0
2/ 90°
Cap: R5W: BA15s in accordance with IEC Publication 60061 (sheet 7004-11A-9)
Electrical4/ and photometric characteristics
Rated
values
Volts 12 24
Watts 2
Test voltage Volts 13.5 28.0
Objective
values
Watts 2 max. 2 max.
Luminous flux 1/, 3/
(in lm at 13.5 V DC) 50 20 %
Luminous flux 1/
(in lm at 9 V DC) 10 min.
1/ The light emitted from LED light source shall be white 2/ To be checked by means of a “box system”, sheet R5W/2_LED 3/ The value measured at elevated ambient temperature of 80C shall be at least 70% of this value 4/ In case of LED light source failure 5/ the electrical current draw, when operated between 12 V and 14 V, shall
be less than 50 mA 5/ Short-circuit between the terminals of the LED retrofit light source is not included
f
Date: 2015-09-11 Submitted by: WGLS chair
16
Category R5W Sheet R5W/2_LED
Screen projection requirements
The following test is intended to define the requirements for the apparent light emitting area
of the LED light source and to determine whether the light emitting area is correctly
positioned relative to the reference axis and reference plane in order to check compliance
with the requirements.
The position of the light emitting area is checked by a box system defined in Figure 2,
which shows the projections when viewing along the direction = 0° (top view) and = +/-
90° (front, rear view) in the plane C0 (C, as defined in Figure 3).
The proportion of the total luminous flux emitted into the viewing direction from the
area(s)
- A, B and C together shall be 70 per cent or more
- B shall be 20 per cent or more
- A and C shall each be more than 15 per cent
Figure 2
Box definition of the light emitting area (top view, front view and rear view)
Table 2
Dimensions of the box system in figure 2 (Front, top and rear view)
Reference a h k
Dimension (mm) 3 4 0.5
A B C a
e
Reference axis
a
h h
k k
Date: 2015-09-11 Submitted by: WGLS chair
17
Category R5W Sheet R5W/3_LED
Normalized luminous intensity distribution
The following test is intended to determine the normalized luminous intensity distribution
of the light source in the C-planes as described in figure 3. The intersection of the reference
axis and the parallel plane to the reference plane in distance e is used as the coordinate
system origin
The light source is mounted on a flat plate with the corresponding holder features. The plate
is fixed to the goniometer table by a bracket, so that the reference axis of the light source
lines up with one of the rotating axis of the goniometer. The corresponding measurement
set-up is described in figure 3.
Luminous intensity data is recorded with a standard photo-goniometer. The measurement
distance should be chosen appropriately in order to make sure that the detector is located in
the far field of the light distribution.
The measurements shall be performed in C-planes, which contain the reference axis of the
light source. The C-planes to be measured shall be C0, C30 and C330. The test points for
each plane and multiple polar angles are specified in Table 3.
The measured luminous intensity values, normalised to the measured luminous flux of the
individual light source under test, shall be converted to normalised luminous intensity
values of a 1000 lm light source. These data shall comply with the tolerance band as
defined in Table 3.
Figure 3
Illustration of C,System
C-planes: see CIE publication 70-1987, "The measurement of absolute intensity
distributions".
Date: 2015-09-11 Submitted by: WGLS chair
18
Category R5W Sheet R5W/4_LED
Table 3
Test point values of normalized intensity in the planes C0, C30, C330
intensity
in cd /1000 lm
Min Max
-100° 60 140
-75° 60 140
-50° 60 140
-25° 60 140
0° 60 140
25° 60 140
50° 60 140
75° 60 140
100° 60 140
The luminous intensity distribution as described in Table 3 shall be substantially uniform,
i.e. in between two adjacent grid points the relative luminous intensity requirement is
calculated by linear interpolation using the two adjacent grid points.
Date: 2015-09-11 Submitted by: WGLS chair
19
Annex 2,
Insert a new paragraph 16.1, to read:
“16.1. For LED retrofit light sources, the following documents, bearing the approval mark
shown above, are attached to this communication:
- Instructions for fitting
- List of vehicle models and lighting functions for which the light source is suitable
- test report by a technical service confirming compliance with paragraph 8.4 of this
regulation”
Annex 3,
Insert a second and third figure for LED retrofit light sources:
“
The above approval mark is an example for the marking of a PY21W LED retrofit light
source”
Annex 4, amend to read:
“Light sources of all categories with integrated heatsink shall be measured in still air at ambient
temperature of (23 ± 2) °C in still air, whereas LED retrofit light sources shall be measured at an
additional ambient temperature indicated in the relevant light source sheet. For these measurements
the minimum free space as defined in the data sheets shall be maintained.
Light sources of all categories with definition of a temperature Tb shall be measured by stabilising the Tb-
point at the specific temperature defined on the category data sheet.
.....“
PY21W LED
Date: 2015-09-11 Submitted by: WGLS chair
20
II. Justification
1. An increasing number of LED retrofit light sources is present in the market, and sold as
replacements for approved light sources.
The public is stimulated by the authorities to use energy efficient lighting like LEDs and is
getting used to LED retrofits in general lighting applications. However, the public is not
aware of and does not understand why automotive LED retrofits in vehicles exterior lamps
bear a safety risk. The public is also not aware that these LED retrofits are not allowed by
many jurisdictions.
On the other hand, there are no legal alternatives for automotive lighting consumers
available, either, nor a way to discriminate the “good” from the “bad”.
2. This is why GTB conducted a feasibility study. GTB reported about the progress of this
study in GRE before and collected feedback; documents GRE-69-41, GRE-70-47, GRE-72-
27 and GRE-73-24.
3. The feasibility study has been finalised and concluded positively. The outcome is reflected
in:
o This proposal to implement provisions into Regulation No. 128, including:
o New category sheets C5W, PY21W and R5W in LED technology;
o Equivalence criteria to guide specifying sheets for LED retrofit light source
categories. These guidelines are intended for publication, with the agreement of
GRE, in the GRE website for “reference documents”, similar to criteria for new
filament light sources for head lighting; document GRE-74-[xx];
o Equivalence reports for the new categories C5W, PY21W and R5W in LED
technology; GRE-74-[xx];
4. As for other light sources is the case, additional tests on voluntary basis are described in
standards as from IEC or SAE.
5. GTB is requesting for advice from Contracting Parties on possible issues related to national
law and possible other legal issues that might arise when introducing approved LED retrofit
light sources.
6. The relevant parts of this proposal can easily be merged with the proposals for
simplification of light source regulations.