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-   -   E46 ZKW Reflector Recall-Open NHTSA Investigation (http://www.bimmerfest.com/forums/showthread.php?t=552978)

edlvrt 07-05-2011 07:42 PM

E46 ZKW Reflector Recall-Open NHTSA Investigation
 
As most of you know, and from what I gather through several internet sites in addition to my experience, the low beam reflectors on 2003-2004 ZKW HID headlights were made of some material that degraded when subjected to the heat produced by OEM Xenon bulbs. This results in a significant decrease in light output as the reflector became scorched. I don't know the exact ins and outs, but I would imagine that BMW and ZKW were and are aware of the defect as the newer, redesigned headlights do not suffer from this problem.

I called the National Highway Traffic Safety Administration (NHTSA) out of curiosity to see if the problem had been noted and if there was anything in the works to fix the defective parts. The gentleman that I spoke with said that an investigation of the issue was opened in 2009, closed at one point, and has been reopened. I gave him my information, VIN, and a description of the problem and the affected cars, and he told me their engineering staff would be sending me their ongoing investigation report with a questionnaire of sorts for me to return with more information on the issue.

He also told me that the more people who report the issue, the greater the chance of some sort of recall. If you suffer or suffered from the headlight issue and have a few minutes to spare, please call the NHTSA at 888-327-4236 to report a vehicle defect. If you would rather not call, there is the option to fill out an online form. Go to http://www.nhtsa.gov/ and click the blue banner to the right "Report a Vehicle or Child Seat Defect," then choose to File an Online Form and go from there.

Thanks

Ed

Coconutpete 07-06-2011 02:23 PM

1: Maybe we have another "subframe type problem" on our hands.

2: Wow - what a first post. You didn't ask about Angel Eyes, what type of oil to use or how to add horsepower for under $250 - nice job!!!!

TerraPhantm 07-06-2011 02:29 PM

Quote:

Originally Posted by Coconutpete (Post 6174798)
1: Maybe we have another "subframe type problem" on our hands.

2: Wow - what a first post. You didn't ask about Angel Eyes, what type of oil to use or how to add horsepower for under $250 - nice job!!!!

Unlike the subframe, I'm not aware of a single case where BMW offered a replacement of the ZKW headlamps after warranty. As far as I'm aware, people under CPO warranty were denied too because the headlights are considered wear components

RSPDiver 07-06-2011 09:15 PM

Quote:

Originally Posted by TerraPhantm (Post 6174810)
Unlike the subframe, I'm not aware of a single case where BMW offered a replacement of the ZKW headlamps after warranty. As far as I'm aware, people under CPO warranty were denied too because the headlights are considered wear components

Seems like a bunch of horse dookie on BMW's part: I've read several e39 M5 owners got their console displays replaced under warranty (regular and CPO) due to missing pixels. Seems to me that functional headlights would be more important than not knowing if it was 89 deg F, or backwards-3-9 deg F. I guess I've been fortunate that I don't do a ton of night driving, and therefore still have apparently functional lights. Would be nice to get a resolution of a known issue, though.

MMME30W 07-06-2011 09:47 PM

Stickied.

ventsyv 07-07-2011 02:05 PM

Quote:

Originally Posted by TerraPhantm (Post 6174810)
Unlike the subframe, I'm not aware of a single case where BMW offered a replacement of the ZKW headlamps after warranty. As far as I'm aware, people under CPO warranty were denied too because the headlights are considered wear components

Does need to be. If it's safety related they'll have to issue a recall.

TerraPhantm 07-07-2011 02:11 PM

Quote:

Originally Posted by ventsyv (Post 6176923)
Does need to be. If it's safety related they'll have to issue a recall.

Agreed.

At the very least, BMW should make it so you could buy the projector bowls without buying the entire assembly. This whole issue wouldn't be a big deal if all it required was the replacement of a $50-100 piece every 5 years or so

edlvrt 07-08-2011 11:25 PM

Thanks for the welcome and the sticky. Hopefully some more/lots of people will get on their horse and make some phone calls...

Quote:

Originally Posted by TerraPhantm (Post 6174810)
Unlike the subframe, I'm not aware of a single case where BMW offered a replacement of the ZKW headlamps after warranty. As far as I'm aware, people under CPO warranty were denied too because the headlights are considered wear components

Perhaps I have not been around cars long enough and I don't have a degree in automotive engineering, but when did headlight assemblies become a "wear" item that require regular replacement for normal, safe vehicle function? I have yet to see it mentioned in any service manual for any vehicle, BMW or not, that the entire headlight needs to be replaced after xx number of hours of service or xx number of days after manufacture. My 1992 E36 did not, my neighbor's 94 Camry still has its original headlights in 100% working order, and my friend's E90 with ZKW HIDs is still shining strong. But for some unexplained reason reason, 2003-2004 BMW E46 sedans (I am citing these model years as I have a 2004 and have read that 2003 sedans are affected as well) with ZKW HID have headlights that "wear out?" Bulbs, yes without question that is understandable, but definitely not reflectors.

If the automotive industry accepts headlights as regular wear items, why did BMW and ZKW bother to change the design for other models and years? The E90 ZKW HID assemblies use a metal reflector that does not degrade over time. From BMW's income perspective, wouldn't it benefit them to continue to produce headlight assemblies that "wear" out and force their customers to shell out over $2000 for replacement? What does it matter from BMW's perspective, as headlights are a "wear" item just like a clutch or windshield wipers, right? Wrong. And BMW knows that.

All auto manufactures have their positives and negatives. BMW is known for their great balance of handling and comfort among other things. The price to pay for these qualities ranges from control arm bushings that go bad soft after a few thousand miles to an appetite for rear tires when compared to your average people mover. Those are understandable. Defective, unsafe headlight assemblies are not.

TerraPhantm 07-09-2011 10:03 AM

Quote:

Originally Posted by edlvrt (Post 6180038)
Thanks for the welcome and the sticky. Hopefully some more/lots of people will get on their horse and make some phone calls...



Perhaps I have not been around cars long enough and I don't have a degree in automotive engineering, but when did headlight assemblies become a "wear" item that require regular replacement for normal, safe vehicle function? I have yet to see it mentioned in any service manual for any vehicle, BMW or not, that the entire headlight needs to be replaced after xx number of hours of service or xx number of days after manufacture. My 1992 E36 did not, my neighbor's 94 Camry still has its original headlights in 100% working order, and my friend's E90 with ZKW HIDs is still shining strong. But for some unexplained reason reason, 2003-2004 BMW E46 sedans (I am citing these model years as I have a 2004 and have read that 2003 sedans are affected as well) with ZKW HID have headlights that "wear out?" Bulbs, yes without question that is understandable, but definitely not reflectors.

If the automotive industry accepts headlights as regular wear items, why did BMW and ZKW bother to change the design for other models and years? The E90 ZKW HID assemblies use a metal reflector that does not degrade over time. From BMW's income perspective, wouldn't it benefit them to continue to produce headlight assemblies that "wear" out and force their customers to shell out over $2000 for replacement? What does it matter from BMW's perspective, as headlights are a "wear" item just like a clutch or windshield wipers, right? Wrong. And BMW knows that.

All auto manufactures have their positives and negatives. BMW is known for their great balance of handling and comfort among other things. The price to pay for these qualities ranges from control arm bushings that go bad soft after a few thousand miles to an appetite for rear tires when compared to your average people mover. Those are understandable. Defective, unsafe headlight assemblies are not.

I never said it's right. I just said that this is what BMW does. I'm sure they say headlamps aren't covered somewhere in the warranty legalese (with the intention being that bulbs not be replaced under warranty) - the language is probably vague enough that they can deny t replacement of headlamp assemblies without violating any contracts.

The situation sucks, but it it is what it is. It's a mostly uphill battle.

edlvrt 07-11-2011 09:42 AM

Quote:

Originally Posted by TerraPhantm (Post 6180535)
I never said it's right. I just said that this is what BMW does. I'm sure they say headlamps aren't covered somewhere in the warranty legalese (with the intention being that bulbs not be replaced under warranty) - the language is probably vague enough that they can deny t replacement of headlamp assemblies without violating any contracts.

The situation sucks, but it it is what it is. It's a mostly uphill battle.

Terra, I hope it didn't come across as me jumping on you, just BMW:thumbup:

I understand that the deck is stacked against us, but the squeaky wheel (sometimes) gets the grease, right? The more people who make some noise, the better our chances.

I will call the NHTSA this week an see where things stand. I don't know if there will be any action or changes in their investigation, but you need to stoke the fire every now and then, right?

bluebee 07-11-2011 02:09 PM

Quote:

Originally Posted by edlvrt (Post 6183982)
I will call the NHTSA this week an see where things stand.

Thanks for the number. I called them (to complain about the BMW PBT-plastic Hella headlight adjusters just now based on this thread - thanks) and they told me how to check up on the number of complaints.

So, if you want to see how many people complained about this E46 ZKW Reflector Recall, they say you can do so here:

- http://www.safercar.gov (click on "VEHICLE OWNERS" & then "Search Complaints")

TerraPhantm 07-12-2011 06:08 AM

Quote:

Originally Posted by edlvrt (Post 6183982)
Terra, I hope it didn't come across as me jumping on you, just BMW:thumbup:

I understand that the deck is stacked against us, but the squeaky wheel (sometimes) gets the grease, right? The more people who make some noise, the better our chances.

I will call the NHTSA this week an see where things stand. I don't know if there will be any action or changes in their investigation, but you need to stoke the fire every now and then, right?

:thumbup: I definitely agree that people should definitely complain about the issue. Part of the problem is that the problem is severe enough that anyone who drives at night cannot really afford to wait for a recall, so they end up replacing the headlights on their own. While I don't own a car with the ZKW headlamps, I have driven a car that had the failed projectors, and it was downright dangerous. My neighbor just retrofitted a set of AL assemblies since it was impossible to see at night otherwise (and he got them for a steal... $250 for both sides with bulbs and ballasts)

mawana 07-12-2011 08:32 AM

I just submitted my complaint.

mujjuman 07-14-2011 06:43 PM

I will call also. Also post this into as many "wth my ZKW" threads too

serge_ua 07-15-2011 02:11 PM

Just submitted my claim online. Thank you edlvrt!

psychocandy 07-15-2011 07:42 PM

The truck delivering my 04 330i ZHP broke down in N. Carolina, about an hour S of Richmond, VA. Picked it up there (long story). The wife and I stopped in Richmond for dinner, then headed home on I-64. As dusk turned into night, I could hardly see and had to pull over to see if the headlamps were actually on. The appeared bright from a glance, but did not project any perceptible beam pattern on to the roadway in front of me. After 2 + hours of straining to see in the twisty mountain roads, I arrived home with a tremendous headache.

I subsequently researched the issue and file complaints with the NHTSA and DOT. I was told by an engineer that the problem that I was going to have was the fact that DOT only regulates that new vehicles (and equipment) and there is no ongoing standard for lighting in terms of maintaining effectiveness over time.

I fought this battle in the forums and with BMW NA to no avail, eventually I sold the car rather than pay a hefty fee for a retrofit or 33% of my purchase price for new lenses.

Ironically, I had a previous 540/6 with the pixel issue on the dash and BMW sent a new unit to a dealership and I only had to pay labor. After that experience, I figured that this issue would be remedied quickly given the obvious safety impact, but to no avail. BMW seems to have changed their strategy in terms of "customer loyalty". If you are very close to the timing of your warranty running out, they will consider making some concession. Otherwise forget about it. Don't even waste your time trying to discuss the difference between wear and non-wear items. The minimum wage worker on the other end of the line most likely doesn't have the capacity to understand you and the supervisor that you will get transferred to will write you off.

akhbhaat 07-16-2011 02:23 PM

FWIW: the ZKW lights were installed in 2005 (at least early 2005s, i.e. sedans) cars as well. My 2005 330i (ZHP) has the ZKW lamps and the bowls are finally starting to burn (they were fine when I bought the car a little over two years ago and the service records don't indicate any sort of replacement--guess the PO didn't drive long distances at night very often).

I'm more than a bit annoyed about this, because it has the potential to be a very expensive problem--and because it already has me adjusting my driving habits simply to extend the life of the bowls. All the dumb little issues I had with my 323i seldom bothered me (easy or cheap to fix), but this is a ridiculous design defect. I should also add that I had OEM AL low beam xenons in that car which saw hundreds of hours of use without issue.

So, I've filed a complaint as well. Thanks for getting the ball rolling on this.

mujjuman 07-17-2011 07:22 PM

i filed out a complaint also

edlvrt 07-19-2011 03:54 PM

Just got off the phone with a lady with the NHTSA. She was able to tell me that BMW issued a service bulletin to somehow correct the issue at the owner's expense, but the head investigator for this issue was not satisfied with the response. She gave me the investigator's name, and a quick google search provided his contact info, so I shot him an email. I'll let you know where this leads.

JJ3699 07-20-2011 05:57 PM

Quote:

Originally Posted by edlvrt (Post 6200543)
Just got off the phone with a lady with the NHTSA. She was able to tell me that BMW issued a service bulletin to somehow correct the issue at the owner's expense, but the head investigator for this issue was not satisfied with the response. She gave me the investigator's name, and a quick google search provided his contact info, so I shot him an email. I'll let you know where this leads.

please keep us updated on this :thumbup:

djs1122 07-23-2011 07:11 AM

I have a 2004 325i sedan with the ZKW lights. I had the burnt bowl problem. For what its worth, after researching possible solutions, I purchased new projectors from theretrofitsource.com. I bought the Infinity-type ones. I cannot recall the exact name of them. I was given a link to detailed instructions to retrofit them into the original headlight housing. It took me a week to complete the job but I was able to do it. It is not difficult, just time-comsuming. My cost for the projectors was $175 and about $20 for misc. other items I needed. A dremel tool is also needed. So for under $200 and about 30 hours of my time, I have bright xenons again.

This is not to say BMW should not address and provide a cure for the ZKW's, but only to tell you there are other options to get the lights fixed rather than go buy used bowls or new ZKW's at $1000 each.

nadodude 07-27-2011 12:01 AM

Did this only affect sedans or coupes/convertibles as well?

G. P. Burdell 07-27-2011 06:14 AM

Quote:

Originally Posted by nadodude (Post 6215113)
Did this only affect sedans or coupes/convertibles as well?

The problem appears to be confined to post-facelift sedans and wagons with bi-xenon headlights manufactured by ZKW.

GaBimmerMan 07-28-2011 07:54 AM

How can you tell if you have ZKW headlights? Is there a marking somewhere? Thanks

RSPDiver 07-28-2011 08:06 AM

Quote:

Originally Posted by GaBimmerMan (Post 6217845)
How can you tell if you have ZKW headlights? Is there a marking somewhere? Thanks

Yep, top of the headlight housing. May be dirty and/or partially obscured by the bracket above, but shine a flashlight in there. If I recall, my driver side light was most visible, and I think it was from the back side.


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