I was starting to research some of the many LED headlight options now being marketed to the masses. I'm on the far downhill side of middle age so my vision at night isn't what it used to be, and as so many have already noted on these forums, there are already many vehicles that appear to be using these aftermarket headlights because the increasingly scattered light is making it challenging for on-coming drivers like me.
From researching one particle LED model that had many very positive reviews, it quickly became apparent that this is a marketing company in China that is pushing many of the right buttons to get the American consumer to believe they have a good product. However, upon further examination there are numerous descriptions and statements that don't stand up.
Some related to the materials used in the heat sink (they say it's aircraft grade "duralumin"; an obsolete and long outdated trade name but it sounds good on first pass and makes good marketing copy. Later I find the aluminum to be a 6063 alloy - perhaps a fitting and good product, but never having the much higher copper percentage that was used in duralumin.
Another area is the light output described as "Luminous flux of 4000lm" (is that number derived at 10 volts, (~13/14 which would be useful) 20, or 30 volts?) The lights are rated to work at all of these voltages and as anyone that has worked with LED's knows, your light output will change as you change the voltage. I suspect the lm at the 13/14 voltage will be no where near the 4000lm in the description.
However, their answering of questions related to the products as being DOT approved and street legal is all I need to know for now.
Title 49: Transportation PART 571—FEDERAL MOTOR VEHICLE SAFETY STANDARDS, is the "law" that applies to headlights and transport lighting in general. It's a long and laborious read with the link at the bottom for those that are doing their research.
What I find of interest is that the China based sellers of the many aftermarket LED headlight options are saying that their headlights are "street legal", "DOT approved" (doesn't happen) or compliant (self certified). However there will be no "DOT" marking on their headlight. There are many hurdles for a headlight to be "street legal" but if there is no "DOT" marking then certainly they cannot be "street legal" in the USA.
You see, the regulation specifically addresses this in section "s11.1 Markings" and requires that: Each replaceable light source must also be marked with the symbol DOT and with a name or trademark in accordance with S6.5.
What is going to be your story after the accident when the other parties attorney ask when you put those illegal headlights on your vehicle? Maybe something else to think about...
Here is the link to all the code:
https://www.ecfr.gov/cgi-bin/text-idx?node=se49.6.571_1108