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In 2003 the NHTSA published a notice of draft interpretation for FMVSS 108 which addresses vehicle lighting. That stated (or at least was interpreted) that fitting HID headlights to any vehicle that didn't come from the factory with HID's was illegal.
Unfortunately, I suppose because of "government speak" combined with wishful thinking on the part of some folks, some people, including HID kit sellers, are taking the 2005 reinterpretation as meaning you can buy HID kits and stick them in your halogen housings. A search of car forums will show a lot of people making that claim. However, a careful reading of the above pdf shows this isn't true, despite people's claims otherwise.
But I decided to go to the source anyway, to make sure.
I contacted the local NHTSA office and it took some time, but yesterday I received a call from an attorney in the DC office who works for Steven P. Wood, chief counsel for the NHTSA, the person who wrote the above document.
What he told me was that I was correct, that you cannot buy an HID kit and install it in your existing halogen housing. Howver, if you can find an off-the-shelf DOT compliant HID assembly that you can replace your entire housing with, then you're fine.
As an example, for a Land Rover Discovery 1 you would have to buy HID units that are a direct replacement for STC1237 and STC1238.
Anything else is illegal in all 50 states.
I asked them if they would consider publishing a simplified human speak version and he said he'd pass the request on to his boss.
He also mentioned that they are getting a lot of calls from law enforcement asking for the same clarification, so even if you don't care that all retrofit kits are illegal, don't assume you won't get stopped by the police for it.
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Tom Rowe
Four wheel drive allows you to get stuck
in places even more inaccessible.
i have learned to just drive directly at them flashing my lights and beeping frantic. maybe they get the idea maybe they don't. either way its good to have this thread to prove the HID conversion people wrong and hopefully change the minds of those who look to do this mod.
__________________ -Ed
99 DII, TF +2" HD & steering damper, TreadWright 265/75/16, ARB front, BritPart rear, Warn m8000 with synth, Columbia Overland gate panel & dual battery tray, Safari snorkel, RoverBones diff guards, RockWare sliders, DieHard Plat Deep Cycle, Chalkboard Headliner, CB, Wilderness Rack, 6 hella 700 ff's w 100w bulbs, 2 hella work lights
93 RRC TF track rod, tie rod & steering damper, TRW rims
The local news channel in Boston did a story on that last month, and they had the same answer, yes you can buy and stick HID light in but they are not legal. They were talking about passing legislation to have inspection stations reject vehicles that were not OEM equipt.
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00 Disco 4.0 80k miles SLS, ACE, 7 passenger 255x65x18: Repairs since 02/11 new intake, valve cover, head, timing cover, waterpump & oil sump gaskets, new timing chain & gears, water pump, t-stat, hoses, belt, new front drive shaft, Akebono pads, D&S rotors, SS brake lines, clutch fan, HMS completed.
90 RRC County
67 mustang GTA
73 Jeepster Commandos
69 Honda SOHC
71 HD FX
72 BSA Lightning
73 Honda SOHC
78 Honda SS
87 HD FLTP
2004 HD SE 103
He who dies with the most toys, WINS
The local news channel in Boston did a story on that last month, and they had the same answer, yes you can buy and stick HID light in but they are not legal. They were talking about passing legislation to have inspection stations reject vehicles that were not OEM equipt.
Wording for such legislation is important as the NHTSA allows the replacement of a complete halogen assembly with a complete HID assembly. If the state writes something contrary to that it may invalidate the complete regulation. States cannot contravene FMVSS 108.
Hopefully they'll just write it that lighting has to comply with FMVSS 108 to pass inspection.
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Tom Rowe
Four wheel drive allows you to get stuck
in places even more inaccessible.
Likely scenario-My car is due for inspection and I have a HID kit installed.
Because I'm have way intelligent I saved my old bulbs.
Before I head to inspection I replace the bulbs.
Pass inspection.
Go back home and put the HID bulbs back.
I know a guy in CA who took a WRX and ripped the emissions off it, put in a racing exhaust and a stage 2 turbo as well as a racing ECU.
Come inspection time he puts the stock exhaust back on and the OEM ecu back.
The turbo make no difference.
Go's back home and rips it all out.
He says its a small price to pay for the added horse power and fun.
It occurred to me that it might be worth adding this to the various tech sections, since the subject keeps coming up.
Also, I neglected to mention that proper HID, or LED, assemblies would be legal for Defenders, RCC's, Series and any other Land Rover with 7" round headlights because you can get the complete housing, reflector, bulb and lens assembly.
__________________
Tom Rowe
Four wheel drive allows you to get stuck
in places even more inaccessible.