Dear Supporters,
Here is an edited response from Claude.AI. "Outdated measurement standards" is the crux of the matter. The luminance of traditional halogen bulbs is inherently limited. LED chips have unlimited luminance from smaller surfaces.
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The regulatory gap for LED headlights presents a distinct challenge. There are significant gaps regarding luminance specifications:
1. Outdated measurement standards: Current regulations for headlights primarily focus on total light output (lumens) and beam pattern distribution rather than surface luminance (cd/m²). For traditional halogen bulbs, this worked adequately because their luminance was inherently limited. LED headlights can produce much higher luminance from smaller surfaces, creating intense glare even while meeting overall light output regulations.
2. Beam pattern vs. source luminance: Regulations like FMVSS 108 in the US and ECE R112/R113 in Europe specify detailed beam pattern requirements (where light can and cannot be directed) but don't adequately address the extreme brightness of the light source itself, which affects peripheral vision and causes discomfort even when the beam is technically "aimed correctly."
3. Retrofitting issues: Regulations haven't kept pace with aftermarket LED conversion kits, which often place high-luminance LED sources in housings designed for lower-luminance halogen bulbs, creating scattered light and glare problems.
4. Testing limitations: Current testing procedures don't adequately capture the real-world effects of high-luminance sources on human vision, especially for vulnerable populations like older drivers whose eyes are more sensitive to glare.
This gap has real consequences, as drivers frequently report discomfort and temporary vision impairment from oncoming vehicles with LED headlights.
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Sincerely,
Mark Baker
President
Soft Lights Foundation
www.softlights.org
mbaker@softlights.org
X: @softlights_org
Bluesky: @softlights-org.bsky.social