Input provided by experts from the GRE TF S/R concerning market surveillance needs for LED replacement light sources. LED replacement light sources enable technology transition from incandescent to LED for vehicles in operation, offering longer lifetime, higher vibration resistance, and lower power consumption. Type-approval framework for LEDr has been established through national approvals and UN R37 approvals. Market surveillance must be improved to ensure only safe, compliant LEDr with type approval are used on public roads. Products without type approval should be offered with correct consumer information and clear restriction for off-road use only. Authorities should remove non-compliant products without type approval if used on public roads.

The Task Force on LED Substitutes and Retrofits reports on establishing a type-approval framework for LED replacements to enable safe technology transition from incandescent to LED lighting for cars-in-use. Step 1 completion has resulted in growing LED replacement category sheets in RE5, with national and UN approvals enabled. Step 2 requires improved market surveillance, as unsafe non-approved products reach roads and some R37-approved products show non-compliance. The task force proposes waiting for front fog cycle completion and applying lessons learnt before enforcing the high beam package, addressing keying deficiencies and inadequate warnings on unapproved products. Market surveillance control points span approval, import, point of sales, PTI, and roadside enforcement.

The draft agenda for the 30th meeting of the GRE Task Force on Substitutes / Retrofits, scheduled for 22 September 2026 from 13:00 to 15:30 CEST online, addresses organisational matters, adoption of the agenda, and reports from the 29th meeting. The agenda covers proposals for R.E.5 including H11 LEDr, H8 LEDr, H16 LEDr, and HB4 LEDr entered-into-force provisions, front fog types completing H10 work, high beam types covering HIR2, HB3, and H9, low beam types, clarification of R37 requirements for LEDr, enforcement and market surveillance matters, and preparation of submissions to GRE95 including category sheets and status reports.

The Task Force on Substitutes/Retrofits reviewed the status of LED retrofit light sources and confirmed a consolidated proposal for four category sheets covering H10, HIR2, HB3, and H9 high beam types. Documents TFSR-29-02 and TFSR-29-03 were agreed for submission to GRE95 as formal and informal documents respectively. The group discussed enforcement and market surveillance issues, including concerns about non-compliant products lacking proper cap keying and approval marking visibility when installed. A status report detailing these non-compliance cases will be prepared for GRE95 consideration.

The GRE Task Force on LED Substitutes / Retrofits prepared proposals for four new LED replacement light source categories: H9_LEDr, H10_LEDr, HIR2_LEDr, and HB3_LEDr, developed in accordance with GRE-91-14 and GRE-94-18 and taking into account equivalence criteria detailed in GRE-83-15. All four categories meet photometric, thermal, and electrical performance requirements using established bi-directional equivalence concepts. H9_LEDr, HIR2_LEDr, and HB3_LEDr employ control point requirements instead of black-top specifications. All four categories have longer area B with modified homogeneity requirements. H9_LEDr contains a single luminous flux specification of 1875 lm at 13.2V to limit impact on beam performance in high-beam and bi-functional applications.

Proposal to amend para. 3.3., Group 5 to add LED replacement light source categories H9, H10, HB3, and HIR2, insert new sheets H9_LEDr/1 to 7, H10_LEDr/1 to 7, HB3_LEDr/1 to 7, and HIR2_LEDr/1 to 7 in Annex 3, and update the Status table to reflect Amendment 13 based on TFSR-28 documents, with H10 proposal based on GRE-94-19, specifications derived from enforced LEDr category sheets and equivalence criteria detailed in GRE-83-15.

The 29th meeting of the GRE Task Force on Substitutes/Retrofits is scheduled for 13 July 2026, 13:00–14:00 CEST, held online via Teams. The agenda includes discussion of the way forward, review of GRE94 report, proposals for R.E.5 covering H11 LEDr, H8 LEDr, H16 LEDr, HB4 LEDr, front fog types including H10, high beam types including HIR2, HB3, and H9, low beam types, clarification of R37 requirements for LEDr, enforcement and market surveillance, preparation and submissions to GRE95, any other business, and next meetings.

The meeting reviewed documents on substitute light sources including H10, HIR2, HB3, and H9 LED retrofit types for UN R.E.5 approval. Category sheets for these types were confirmed. The Task Force agreed to submit four category sheets as a single formal document to GRE with justification in two parts. Market surveillance activities were discussed with CITA, WP29 IWG on PTI, EU Forum on Market Surveillance, and UK authorities to identify approved or non-approved LED retrofit products. A follow-up meeting was scheduled for 13 July 2026.

This document defines essential dimensions, electrical characteristics, and photometrical requirements for LED light source category H9. The LED light source shall not exceed the specified envelope and shall function in either voltage polarity. Rated values include 26 watts at 12 volts and 26 watts minimum at 13.2 volts, with minimum luminous flux of 2000 lm and cap temperature not exceeding 100°C. The luminous flux measured at elevated ambient air temperature shall be at least 75% of objective luminous flux. The document specifies screen projection requirements, contrast requirements, and normalized luminous intensity distribution requirements across defined C-planes and test points.

Based on LS-1691, this document defines specifications for HB3 LED light sources. LED light sources shall not exceed the specified envelope, function in either voltage polarity, and be rotated in the measuring holder until the reference lug contacts the holder plane. Essential electrical and photometric characteristics include rated values at 12V and 13.2V, with minimum luminous flux of 2000 lm and cap temperature limits. Luminous flux measured at elevated ambient air temperature shall be at least 75% of objective luminous flux. Screen projection requirements specify box system proportions for light emitting areas and contrast limits. Normalized luminous intensity distribution shall comply with specified limits in defined C-planes when measured at test voltage.

This document defines category HIR2 LED light source specifications. The LED light source shall not exceed the envelope indicated in Figure 2, be concentric to the reference axis, and function in either voltage polarity. Essential characteristics include rated values at 12 volts DC of 26 watts power and 2000 lm minimum luminous flux. Cap temperature shall not exceed 63°C at test voltage or 100°C at elevated ambient air temperature. Luminous flux measured at elevated ambient air temperature shall be at least 75% of objective luminous flux. Light emitted shall be white. The contrast proportion of luminous flux shall be 100 minimum. Normalized luminous intensity distribution shall comply with specified limits in C-planes.

This document specifies requirements for category H₁₀ LED light sources with PY20d caps. The light source shall not exceed the outlined envelope and shall function in either voltage polarity. Essential characteristics include rated values of 12 volts and 21 watts, with luminous flux of 1500 lm minimum at test voltage. The luminous flux measured at elevated ambient air temperature shall be at least 75% of objective luminous flux. Screen projection requirements define light-emitting area positioning using box systems. Normalized luminous intensity distribution requirements are specified in C-planes with defined test points and minimum/maximum intensity values in cd/klm.

Revision of TFSR-26-03 addresses H9 LEDr flux considerations and dual-voltage specification. The document proposes applying a single specification for H9 LEDr: 1875 lm ±10% @13.2V, representing a compromise between high-beam and low-beam applications. This luminous flux level is not critical, as high-beam measurements with H9 filament bulbs exceed legal minimums by more than 10%, and low-beam safety margins remain acceptable with limited flux increases. Additionally, a black-top limit of 50 cd/klm at control point zero is proposed for bulbs without black-top specification, and LEA sub-zone specifications (B1, B2, B3) for high-beam categories should be optimized to support beam performance.

LED replacement light sources without type approval are being sold online and offline and are unsafe for public roads; vehicles equipped with such products would fail PTI. LED replacement light sources with type approval are available either at national level or according to UN R37, and are safe and legal for public roads; vehicles equipped with approved LED replacement light sources shall NOT fail PTI. Approval marking on installed light sources is not accessible during PTI; verification may involve a sticker on headlamp housing, type approval documents, or packaging, with removal of the light source as a last resort to verify the approval marking.

The Task Force on Substitutes/Retrofits held its 27th meeting on 20 April 2026. The agenda TFSR-27-01 was adopted with focus on agenda item 10. The report of the 26th meeting TFSR-26-05 was confirmed. GTB WGLS will continue work on category sheet proposals for high beam cluster, anticipated for submission by end of May. H11 LEDr entered into force in November 2024; H8 LEDr, H16 LEDr, HB4 LEDr entered into force March 2026. Document TFSR-27-02 was reviewed page-by-page and agreed changes implemented; the secretary was asked to submit this document and the draft H10 LEDr proposal to GRE94 as informal documents. The next meeting is planned for 15 June 2026.

The Task Force on LED Substitutes/Retrofits reports on progress toward GRE-94. Completed actions include LED Substitutes (Step 1) and LED Replacements/Retrofits (Step 2) with administrative and technical items. Front Fog cluster H8, H16, HB4 was approved by WP29 in March 2026 and entered into force. High Beam cluster HB3, HIR2, H9 and H10 discussions began in WGLS in November 2025, with presentations to TF S/R in March 2026. H10 LEDr draft category sheet is submitted as informal document. Market Surveillance identified as necessary support activity, addressing control points from manufacturer to road including approval, import, point of sales, PTI, and enforcement.

The meeting reviewed proposals for LED retrofit (LEDr) categories including H10 front fog lights and H9 high beam types for Regulation 37/RE.5. Key discussions addressed H10 failure requirements, H9 dual-voltage flux levels, and homogeneity requirements for B-type boxes. The task force also focused on market surveillance and enforcement mechanisms to ensure only approved LEDr products are used on public roads. The next meeting is scheduled for 20 April 2026.