LED Retrofit Fast-track proposal and feedback W. Schlager Karlsruhe, 23-July-2015
Introduction = Motivation ECE R37-compliant light source ECE compliant device True LED retrofit Pseudo non-approved LED retrofit Target: R128 homologation Compliant device performance! Approval number, legal product to safely replace filament bulb ECE-compliant replacement part ECE-compliant device Exist in markets today Non-compliant device performance! Consumers not aware of safety-risk Non-compliant part non-compliant, illegal device
Review: The assignment (Seattle, Oct 12) Proposal: For filament light sources, the evaluation procedure for introducing new categories into Regulation No. 37 has been described by GTB and published in the GRE website under reference documents. A similar approach should be taken for the introduction of LED light sources, in particular for LED retrofits. This subject of LED retrofits has been initiated and discussed during the last two WG LS meetings in May and July after CE met in May 2012. It was then decided to ask CE approval for a new work item: Feasibility of LED retrofit categories The work item should include: Development of equivalence criteria, acceptable for GRE, showing that the proposed LED retrofit category shows equivalent performance as the corresponding light source category specified by R37. Determine a benchmark of filament lamps to which the LED retrofit should be equivalent within specified tolerances. Consider application aspects that are not prescribed by R37, but in other regulations or standards. Select one or two candidate categories to verify such method. Investigate how to implement retrofit provisions in the relevant UN regulations From an administrative and legal perspective. From the referencing perspective from other national or regional law. CE-4792
Review: The Outcome (Bruges, May 2015) R128 proposal incl. C5W, PY21W, R5W Definition Marking Provisions Not for T.A., not for CoP Instructions Failure detection system Spectral content List of vehicles and functions Equivalence reports CE-5114 GTB-119-15 Ref. document Equivalence Criteria Same parameters Similar parameter Intensity distribution Size, position, homogeneity of LEA Different parameters Power consumption Spectral content of white Additional parameters Thermal behavior CE-5115 + EMC + thermal management of device Fast-track CE-5134 GTB-119-10 GTB-119-36 from DE from NL
List taken from LS-xxxx I. Photometry? II. Failure mode A. Open circuit/ close circuit? B. All aspects? III. Spectrum for white LED retrofits behind coloured filters IV. Thermal management (Par. 8.5 and IEC test) V. Vibration test VI. Hot ambient temperature flux A. 80/100 C B. Close to halogen head lighting light source VII. Behaviour when start/stop system is working VIII. Flux at voltage drop IX. ANY OTHER QUESTION OR ISSUE?
SUMMARY taken from LS-xxxx Legal I. How to be sure that customers...not in the positive list... II. Who is responsible for malfunctioning and... III. IV. Disclaimer in proposal is not watertight... Who will check conformity... V. How to be sure all lamps are tested... VI. Image of vehicle brand... VII. Vehicle manufacturers do not take extra cost, effort or risk... Not for discussion in GTB WG LS but some remarks on the positive list
In general: Address topics in the proven way Safety-related UN R37 / R99 / R128 Maximum outline Luminous flux Max wattage Size and position of LEA Intensity distribution Cap / Connector Voltage range Thermal behavior (1min/30min) Min. performance of replaceable LS s IEC IEC 60810 Lifetime testing Vibration / Shock Mechanical strength Electrical stress Thermal stress EMC Exceeding requirements customer specification e.g. OEM specs Minimum lifetime (B3, B10) Electrical overstress tests Extended voltage range Temperature range ESD protection Mechanical robustness Handling / packaging
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Photometry The equivalence between the filament light source and the LED retrofit light source of the same category is the core of the chosen approach CE-5114 (see assignment CE-4792 and outcome ) CE-5115 Testing on lamp level is not required, nevertheless Rear turn (S. Schwaiger) Front turn demo (Geneva, Bruges)
Intensity Distribution derive min/max from filament samples Example: PY21W filament samples in all three C-planes Origin: Stockholm, May 13 LS-0869 Investigate homologated filament samples Derive min. and max. intensity limits GTB-119-15 11
Size, position, homogeneity of LEA derive from filament box specs Origin: Torino, Feb 14 LS-0926 GTB-119-15
Positive list The positive list approach allows only functions/vehicles without (issue of) failure detection, and with proper spectral balance LS manufacturers are fully responsible for the optical performance of the retrofit and the correctness of the positive list. LS manufacturers check the proper function per listed function/vehicle LS manufacturers verify via exchange with carmaker or test in (rental) car or.. Consumers are used to such lists (wipers, tyres, ) with very clear information:... in the language of the country where the light source is sold... at the point of sale, clearly visible, without removing...... reference made using symbol Test houses / authorities have the right to check or ask for proof
Failure mode The positive list approach allows only functions/vehicles without issue with failure detection or - of course - without failure detection LS manufacturers are fully responsible for the correctness of the positive list. LS manufacturers check the proper function per listed function/vehicle LS manufacturers verify via exchange with carmaker or test in cars Consumers are used to such lists (wipers, tyres, ) with very clear information:... in the language of the country where the light source is sold... at the point of sale, clearly visible, without removing...... reference made using symbol Test houses / authorities have the right to check or ask for proof
Power consumption Forbid manipulation, limit use P max (W) 30 25 Example: PY21W Exclude manipulations (hardware, software) Only allow for certain vehicles/functions 20 15 10 5 0 Typical detection limit of failure detection systems Filament R37 LED R128 Can be an issue in some vehicles
Failure detection system Limit the use to certain vehicles and function CE-5115 CE-5115 CE-5114
Add a clarifying footnote to category sheet same as used for LR3, LR4, Electrical characteristics In case of LED light source failure (no light emitted) the max. electrical current draw, when operated between 12 V and 14 V, shall be less than 20 ma (open circuit condition). Note: LED light sources have a very high chance of an open failure, whereas a short failure is very unlikely. There is no basic difference to filament light sources, which also have a very low chance of a short failure.
Thermal requirements Two concerns: 1. Thermal management of the lamp/device 2. Photometrical behavior of retrofit under elevated ambient temperatures Such kind of tests do not exist in any single case (replaceable, non-replaceable, modules) in UN ECE If safety-relevant, then tests should be introduced in UN regulations for all light source solutions
Thermal behavior derive from filament base conditions 2. Drive filament bulb (R10W) at nomimal 1. Prepare holder / backplate P = 8,84 W T1 Same thermal situation at holder with 23% of power T2 T1 at metal trace T2 at plastic holder outside P = 2,02 W 3. Tune LED retrofit to achieve same temperature
Thermal behavior derive from filament base conditions 3.3.1. Maximum electrical power consumption The maximum electrical power consumption of an LED retrofit light source shall be limited to a value of about 30% of the maximum power specified in the corresponding data sheet of Regulation No. 37 in order to limit the heat load in the cap at a level comparable to the corresponding filament light source. This value may be specified more precisely, for example via comparative temperature measurements. When placed in a typical holder and operated at the properly specified maximum power the cap temperature of an LED retrofit light source shall stabilise at similar (or lower) value as for the corresponding filament light source placed in the same holder and operated at objective power. CE-5115 3.4.1. Thermal behaviour The thermal behaviour of the emitted luminous flux after one minute of operation and after 30 minutes of operation shall be in accordance with Regulation No. 128, annex 4.
Concern 1: thermal management of lamp/device facts!? Probably it is not mainly about getting water or humidity out of a lamp/device but more about the pumping cycle waterin/out due temperature cycles? If so, then the issue would be smaller with the use of low power retrofits
Concern 1: thermal management of lamp/device facts!? Some experts confirm complexity of the topic; it seems to be not clear whether worse or better after retrofit insertion One setmaker confirms no worry There seems to be no unequivocal understanding. If something is not clear, then usually no regulation changes are made
Concern 1: thermal management of lamp/device consider performance testing If thermal management of the lamp/device should be tested Note the discussion [8.5], whether an additional requirement is needed (GTB-119-10, GTB-119-36) Add IEC performance test and requirement for all lamps/devices, including the retrofit case
Concern 2: behaviour under elevated ambient T. consider additional requirement High external thermal load or the proximity of filament bulb will increase ambient temperature Additional requirement could be considered First tests in different headlamps and rear lamps have shown realistic ambient conditions of up to 50 C Add e.g. a footnote in category to verify the luminous flux at an additional ambient temperature of 60 C
Spectral content Only white LED retrofit light sources having a different spectral balance can create an issue if used behind colored lenses If the CCT of the white LED retrofit light source is specified above 3000K, then the spectral fitness is covered by the positive list CE-5114 CE-5115
Spectral content Either warm-white, or limit the use White LEDs with different CCT CCT intensity Comparing investigation: (with kind support from Mr Torma) typical red filter lens If CCT > 3000K, then the red content to be checked!
Vibration Such kind of tests do not exist in any single case in UN regulations The vibration topic is considered under performance (IEC) not under safety
Vibration resistance no issue expected, but limitation conceivable No problem expected due to first tests Dynamic load on holder is higher due to higher weight and different center of gravity, but a first test has shown no issue, even under heavy-duty conditions Comparison in PY21W case: ~ 4x higher load (retrofit vs. filament bulb) but no issue with the holder-system Deflection strength test Nevertheless, voluntary requirement conceivable e.g. limit weight for HIDs with integrated starter e.g. limit weight and center of gravity for fully integrated HID
Voltage dependence All LED light source categories in R128, incl. Retrofits, (will) have a minimum flux over voltage stability In general, in the range of 12-14V in Annex 4 or specifically, e.g. 9-16V in LR1 data sheet
Voltage dependence minimum flux requirement An additional minimum requirement for the luminous flux in case of voltage drop Comparable to requirements for LR3, LR4, at 9V ~20% of the objective flux at 13.5V Performance comparable to the filament case
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