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E46 (1999 - 2006)
The fourth generation 3 Series (E46 chassis) was introduced in 1999 and set the standard for engineering and performance during it's years of production including being named to Car & Driver's 10 best list every one of those years! ! -- View the E46 Wiki

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  #1  
Old 07-05-2011, 06:42 PM
edlvrt edlvrt is offline
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Exclamation 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
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  #2  
Old 07-06-2011, 01:23 PM
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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!!!!
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  #3  
Old 07-06-2011, 01:29 PM
TerraPhantm TerraPhantm is offline
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Quote:
Originally Posted by Coconutpete View Post
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
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Old 07-06-2011, 08:15 PM
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Originally Posted by TerraPhantm View Post
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.
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Old 07-06-2011, 08:47 PM
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Old 07-07-2011, 01:05 PM
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Quote:
Originally Posted by TerraPhantm View Post
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.
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  #7  
Old 07-07-2011, 01:11 PM
TerraPhantm TerraPhantm is offline
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Originally Posted by ventsyv View Post
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
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Old 07-08-2011, 10:25 PM
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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 View Post
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.

Last edited by edlvrt; 07-08-2011 at 10:35 PM.
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  #9  
Old 07-09-2011, 09:03 AM
TerraPhantm TerraPhantm is offline
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Quote:
Originally Posted by edlvrt View Post
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.
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Old 07-11-2011, 08:42 AM
edlvrt edlvrt is offline
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Quote:
Originally Posted by TerraPhantm View Post
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

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?
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Old 07-12-2011, 07:32 AM
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I just submitted my complaint.
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  #12  
Old 07-14-2011, 05:43 PM
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I will call also. Also post this into as many "wth my ZKW" threads too
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Old 07-15-2011, 01:11 PM
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Just submitted my claim online. Thank you edlvrt!
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Old 07-15-2011, 06:42 PM
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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.
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Old 07-16-2011, 01:23 PM
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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.
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Old 07-17-2011, 06:22 PM
mujjuman mujjuman is offline
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i filed out a complaint also
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Old 07-19-2011, 02:54 PM
edlvrt edlvrt is offline
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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.

Last edited by edlvrt; 07-19-2011 at 02:56 PM.
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  #18  
Old 07-20-2011, 04:57 PM
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Quote:
Originally Posted by edlvrt View Post
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
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Old 07-26-2011, 11:01 PM
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Did this only affect sedans or coupes/convertibles as well?
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Old 07-27-2011, 05:14 AM
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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.
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  #21  
Old 07-28-2011, 06:54 AM
GaBimmerMan GaBimmerMan is offline
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How can you tell if you have ZKW headlights? Is there a marking somewhere? Thanks
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Old 07-28-2011, 07:06 AM
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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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Last edited by RSPDiver; 07-28-2011 at 07:08 AM.
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Old 07-28-2011, 08:16 PM
TerraPhantm TerraPhantm is offline
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ZKW's also have clear projector lenses while the AL/Bosch projectors have frosted lenses with a line going across the middle.
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Old 07-30-2011, 12:01 AM
Shrike Shrike is offline
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It seems as if ZKWs and ALs were used interchangeably on HID equipped cars. I've got an '04 sedan with factory original AL lights, while plenty of other '04 330i sedans came with ZKW lights.
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Old 08-02-2011, 03:24 PM
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Does anyone know if this defect was ever fixed by ZKW? That is, if I decide to bite the bullet and change the headlights, will it make sense, or they will burn out again?
Another question: can I put AL in place of ZKW?
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