ECE R37 applies to globes illuminated by a heating filament. I don't think by construction, an LED globe is eligible for ECE R37 testing.
Sounds about right though I haven’t read the doc…
And therein lies the problem with the regs where the technology had been quantified in the regulations itself rather than the expected outcomes, like mechanical packaging, bulb light output, bulb beam spread, headlamp beam spread, headlamp beam cutoff, test methodology, etc…
The problem here is that a LED H4 globe can never be compliant with the regulations and thus the globe can never be compliant and thus the headlamp assembly and globe can never be compliant. So it seems that Phillips takes a piecemeal approach and provides a docs that verify that their adapter globe and a specific vehicle headlamp assembly complies with the intent of the regulations and the vehicle owner should carry that doc in their glovebox (in case they are questioned by police)… The problem being that such sloppy certification process must be done vehicle by vehicle and can be a PITA if the cop is obstinate and doesn’t understand what’s being provided…
Regs can be a bit of a clusterfuck at times and can leave a vehicle owner in a bit of a pickle .. I just consider the drama one Hyundai i30N driver had in the USA when a policeman ticketed him for driving a noisy non compliant car (which needed corrective fix according to the regulator but the manufacturer said there was nothing to fix; catch 22) … It took him quite a while (almost a year?) to sort out and that only happened when the media got involved. Obviously with a headlamp bulb, you’d just remove it and insert a halogen one and get an inspection but it’s all a PITA if on the rare occasion you get pulled over, all because regulations are updated so slowly that polar ice caps seem to melt quicker in comparison
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