Important Information Manual

For more information related to Philips LED range, please contact us www.philips.com/support or contact your local representative.
11
modifications to the vehicle. Despite the superior performance of Philips LED retrofit bulbs, your vehicle may not
pass the inspection with LED retrofit installed because the bulbs are not yet certified for use on public roads.
4.6. Why now sell LED retrofit bulbs in countries previously considered “no trade”?
When we first introduced LED retrofit bulbs, we decided on a limited launch. After two years’ experience of selling
LED retrofit bulbs in certain EU countries, we now feel that the time has come to open up sales to other countries
as well. Although regulations have not changed, we believe that we have provided our customers with sufficient
information to confidently sell LED retrofit bulbs.
4.7. What is the specific regulation that LED retrofit bulbs must conform to?
Today the retrofitting of halogen, xenon and LED bulbs is not allowed by existing legislation. In the EU, automotive
parts must be certified to UNECE specifications for use on public roads. Current ECE certifications only apply to
halogen, xenon and LED bulbs installed in new vehicles:
- ECE R37 for OEM halogen
- ECE R99 for OEM Xenon
- ECE R128 for OEM LED
However, there are no specific homologation requirements for, or restrictions to, using LED retrofit bulbs on
private roads.
4.8. What is the impact of R128, and why do Philips LED retrofit bulbs not fulfill these requirements?
ECE R128 is the certification for LED optics, meaning that the headlamp has been developed with LED as its light
source. The regulation doesn’t apply to LED retrofit used to replace halogen bulbs certified under ECE R37.
4.9. Who bears responsibility when a consumer is found with LED retrofit bulbs on a public road?
Assuming the consumer has been properly informed of the restrictions that apply and that the consumer has
installed the LED retrofit bulbs themselves, it is in principle the consumer’s sole responsibility. However, local
authorities may take action over the sale of LED retrofit bulbs for use on public roads. The extent of that action
depends on the powers given to the local authorities.
4.10. Are there any legal LED retrofit bulbs available? (Other suppliers sell LED retrofit bulbs, claiming they are
legal.)
No LED retrofit products are currently legal on public roads in the EU unless the bulbs are sealed in their housings
and both bulb and housing have been approved for use together.
4.11. What do these symbols on the packaging mean?
This symbol indicates that the product is not suitable for public roads. This means
that it can only be used on “closed” roads.
This symbol shows that the product has not been approved according to the ECE
R37 regulation on halogen bulbs. We show the halogen regulation because,
although an LED retrofit bulb is designed to replace the halogen bulb in the very
same headlamp unit, that does not mean the LED retrofit bulb is ECE R37-
approved.