E46 ZKW Reflector Recall-Open NHTSA Investigation

ZKW's also have clear projector lenses while the AL/Bosch projectors have frosted lenses with a line going across the middle.

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.

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?

Originally Posted by serge_ua

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?

During the E46 production, it wasn't fixed. The E90s apparently use a similar projector that doesn't exhibit this problem. I'm not sure if ordering a brand new ZKW assembly through BMW would have fixed bowls

http://forum.e46fanatics.com/showthread.php?t=845704

Originally Posted by serge_ua

Another question: can I put AL in place of ZKW?

Yes. If you do a search, you'll find my notes on the swap.

Originally Posted by TerraPhantm

During the E46 production, it wasn't fixed. The E90s apparently use a similar projector that doesn't exhibit this problem. I'm not sure if ordering a brand new ZKW assembly through BMW would have fixed bowls

http://forum.e46fanatics.com/showthread.php?t=845704

TerraPhantm, thanks a lot for the link! I think I'll make a retrofit from E90 as soon as I find the parts on eBay.

Originally Posted by G. P. Burdell

Yes. If you do a search, you'll find my notes on the swap.

Hey G. P., I saw your note about discoloration of AL covers:

http://www.bimmerfest.com/forums/sho...d.php?t=501726

I guess I'll go with E90 retrofit.

Originally Posted by TerraPhantm

The E90s apparently use a similar projector that doesn't exhibit this problem.

http://forum.e46fanatics.com/showthread.php?t=845704

Very interesting - thanks for posting the link. Random thoughts:

I'm not sure I like the idea of modifying the bulb holder to accommodate a D2S bulb.

Is a projector designed for a D1S bulb going to have any output issues when a D2S bulb is installed?

Has anyone measured the dimensions of the projectors/reflectors/lenses? If the bulb-to-lens distance is different, or if the lens designs are different, then I would rather retrofit the entire projector, lens and all, to optimize the light output.

A poster in the U.S. said he could not get the E90 projector mounting holes to line up like the thread starter did. Are there design differences between ECE and U.S. bi-xenon projectors for the E90?

Have there been any reports of burning or peeling of the chrome reflector coating in E90 projectors that have a lot of hours on them? If the reflector is an identical (or very similar) design, ZKW would have had to select a more robust coating in order for the reflector to take the heat from the bulb. They may have incorporated other design features into the E90 design (e.g., more ventilation of the housing for better cooling of the projectors) that might not be carried over when retrofitted to an E46.

This discussion probably belongs in its own thread rather than in a thread about sharing info with NHTSA.

Originally Posted by G. P. Burdell

Very interesting - thanks for posting the link. Random thoughts:

I'm not sure I like the idea of modifying the bulb holder to accommodate a D2S bulb.

Is a projector designed for a D1S bulb going to have any output issues when a D2S bulb is installed?

Has anyone measured the dimensions of the projectors/reflectors/lenses? If the bulb-to-lens distance is different, or if the lens designs are different, then I would rather retrofit the entire projector, lens and all, to optimize the light output.

A poster in the U.S. said he could not get the E90 projector mounting holes to line up like the thread starter did. Are there design differences between ECE and U.S. bi-xenon projectors for the E90?

Have there been any reports of burning or peeling of the chrome reflector coating in E90 projectors that have a lot of hours on them? If the reflector is an identical (or very similar) design, ZKW would have had to select a more robust coating in order for the reflector to take the heat from the bulb. They may have incorporated other design features into the E90 design (e.g., more ventilation of the housing for better cooling of the projectors) that might not be carried over when retrofitted to an E46.

This discussion probably belongs in its own thread rather than in a thread about sharing info with NHTSA.

G.P, I just did this retrofit and I have to say you worry too much. If it's light you need, with this mod, you will get it. I can't say how the light output would compare to one from an entire e90 housing but it's more than adequate and for a lot less than getting the entire e90 projector assembly. Once you retrofit them, all you have to do is to adjust the knobs to make sure the light is spread and aimed properly [just find a wall where you can move the car 30ft to 60ft while doing the adjustments.]

As for the e90 to e46 projector mounting holes, the top ones line up perfectly as long as you get Left and Right sided housings. If for whatever reason you are forced to reverse the orientation, say putting a L into the R-side, slight adjustments to enlarge one or two holes on the 'wrong' housing are necessary.

Originally Posted by mawana

G.P, I just did this retrofit and I have to say you worry too much. If it's light you need, with this mod, you will get it. I can't say how the light output would compare to one from an entire e90 housing but it's more than adequate and for a lot less than getting the entire e90 projector assembly. Once you retrofit them, all you have to do is to adjust the knobs to make sure the light is spread and aimed properly [just find a wall where you can move the car 30ft to 60ft while doing the adjustments.]

As for the e90 to e46 projector mounting holes, the top ones line up perfectly as long as you get Left and Right sided housings. If for whatever reason you are forced to reverse the orientation, say putting a L into the R-side, slight adjustments to enlarge one or two holes on the 'wrong' housing are necessary.

PM sent

Originally Posted by mawana

G.P, I just did this retrofit and I have to say you worry too much.

I'm glad you posted your comments on your retrofit. As with my other projects, I try as much as possible to install high-quality components that'll last longer than the ones they replace. I posted all of those questions because this particular retrofit seems to be very new, with relatively little information on the design of the E90 projector or how well the retrofit holds up in the long run.

I hope you'll continue to post your thoughts after the components have logged more hours!

Originally Posted by G. P. Burdell

Very interesting - thanks for posting the link. Random thoughts:

I'm not sure I like the idea of modifying the bulb holder to accommodate a D2S bulb.

Is a projector designed for a D1S bulb going to have any output issues when a D2S bulb is installed?

Has anyone measured the dimensions of the projectors/reflectors/lenses? If the bulb-to-lens distance is different, or if the lens designs are different, then I would rather retrofit the entire projector, lens and all, to optimize the light output.

A poster in the U.S. said he could not get the E90 projector mounting holes to line up like the thread starter did. Are there design differences between ECE and U.S. bi-xenon projectors for the E90?

Have there been any reports of burning or peeling of the chrome reflector coating in E90 projectors that have a lot of hours on them? If the reflector is an identical (or very similar) design, ZKW would have had to select a more robust coating in order for the reflector to take the heat from the bulb. They may have incorporated other design features into the E90 design (e.g., more ventilation of the housing for better cooling of the projectors) that might not be carried over when retrofitted to an E46.

This discussion probably belongs in its own thread rather than in a thread about sharing info with NHTSA.

Assuming you can design an adequate retention mechanism, a D2S and D1S bulb would have identical lighting properties. The capsules themselves are identical; the arc will be at the same point. If you look at the bases, they're even notched in the same manner. D1S only came about because it makes more sense from a safety perspective to have the ignitor integrated into the bulb. IIRC even D3S/D4S bulbs have the same dimensions, so really any proper HID projector would have optical properties that are appropriate for any proper HID bulb. The only differences will be in the actual retention mechanisms (and notches in the case of the D3S and D4S bulbs). It probably wouldn't be very difficult to retrofit D1S ballasts if you didn't want to hack together a D2S mounting mechanism.

I'm not sure if the projector bowls or lenses differ significantly in terms of dimensions and focal length. The bowl itself seems to be constructed of metal rather than plastic, which seems to be key in the projector burning issue.

It is possible that the LHD and RHD projectors have slightly different mounting points. The RHD projectors have and adjustment to make the cutoff flat for driving into LHD countries. The LHD projectors have no such feature.

Bump. Well I think we can all see that the DOT/NHTSA take lighting issues seriously after the recent E46 tail light recall. Many automotive componants are not covered by NHTSA federal motor vehicle safety standards (FMVSS), but lighting (and reflectors) are (FMVSS 108), therefore the NHTSA takes special note of non-compliance issues. Unfortunately, E46 owner's since 2009 paid millions of dollars collectively to pay for the defective ground fault issue with the 6-pin connector, but now some relief is in sight with the recent recall. As stated in here...make your complaint to the NHTSA web site, and in the meantime KEEP YOUR RECEIPTS for any out-of-pocket repairs.

Originally Posted by pointandgo

Bump. Well I think we can all see that the DOT/NHTSA take lighting issues seriously after the recent E46 tail light recall.

Funny I stopped by local dealer and asked about this recall. They don't have it in their system.
They plugged my key in scanner to see if there are recalls and nothing came out. At least that is what they say. They printed paper with history what was done to my car so far (I am new owner) but they did not want to give me record when I asked for it.
Why would not give me record of my car?

Update...

Yesterday I received a letter from the NHTSA stating that there is not enough evidence of 2004 330s with defective headlights to warrant a safety investigation. So apparently there never was an investigation....

I am composing a letter in response to the one I received stating that the issue is not limited to 2004 330s but all E46s (1999-2006). I also want to stress to them that me driving 45 on the interstate at night is more of a safety concern than the tail lights, which have received the appropriate attention. If you want the name and mailing address so you can write as well, PM me.

Keep calling in, sending online complaints, and mailing letters. They are listening, but they need to hear from more people. Be sure to make note of any near misses or accidents due to your lack of visibility at night.

Thanks

Originally Posted by edlvrt

Update...

Yesterday I received a letter from the NHTSA stating that there is not enough evidence of 2004 330s with defective headlights to warrant a safety investigation. So apparently there never was an investigation....

I am composing a letter in response to the one I received stating that the issue is not limited to 2004 330s but all E46s (1999-2006). I also want to stress to them that me driving 45 on the interstate at night is more of a safety concern than the tail lights, which have received the appropriate attention. If you want the name and mailing address so you can write as well, PM me.

Keep calling in, sending online complaints, and mailing letters. They are listening, but they need to hear from more people. Be sure to make note of any near misses or accidents due to your lack of visibility at night.

Thanks

The VERY KEY POINT is that every owner experiencing a problem report it to NHTSA's complaint database utilizing the complaint form that they provide (their web site). It DOESN'T take hundreds of complaints to get NHTSA's attention necessarily...especially if the component is covered by a federal motor vehicle safety standard (FMVSS), and therefore under NHTSA's authority. Many vehicle components are not (HPFP for example). DON'T GIVE UP!
Remember, NHTSA's main mission is automotive SAFETY, especially with regard to the FMVSS that they are guardians for. They DON'T want to get caught with they pants down.

One thing that may help our cause is if when you report, don't limit yourself to a 2004 330 or whatever you have. Tell them you have an E46, and that the problem is found in all E46s from 1999-2006 with the ZKW headlights.

Cheers

Originally Posted by edlvrt

One thing that may help our cause is if when you report, don't limit yourself to a 2004 330 or whatever you have. Tell them you have an E46, and that the problem is found in all E46s from 1999-2006 with the ZKW headlights.

Are the pre-facelift (1999-2001) "single" xenon headlights burning, too? I had thought the issue was limited to the 2002-2005 facelift sedans with bi-xenons manufactured by ZKW.

I understand that it is the face lifted cars that have the bad reflectors, but I worry that if we limit our reports to a single model year, the NHTSA won't think it is a broad enough defect to start and investigation.

Originally Posted by edlvrt

I understand that it is the face lifted cars that have the bad reflectors, but I worry that if we limit our reports to a single model year, the NHTSA won't think it is a broad enough defect to start and investigation.

I understand your concern that this defect will drop off of NHTSA's radar screen. However, as one who partially funds NHTSA with my tax dollars, I would prefer to see the agency conduct an efficient investigation based on real data - that is, based on real complaints filed by affected 2002-2005 sedan owners. Exaggerating the scope of the defect by including four unaffected model years doesn't seem like a productive way to keep NHTSA's interest.

Have you posted your appeal to any other enthusiast forums besides this one, such as Bimmerforums, E46Fanatics, or ZHPMafia? You might be able to encourage more 2002-2005 owners on those forums to file complaints.

Originally Posted by G. P. Burdell

I understand your concern that this defect will drop off of NHTSA's radar screen. However, as one who partially funds NHTSA with my tax dollars, I would prefer to see the agency conduct an efficient investigation based on real data - that is, based on real complaints filed by affected 2002-2005 sedan owners. Exaggerating the scope of the defect by including four unaffected model years doesn't seem like a productive way to keep NHTSA's interest.

Have you posted your appeal to any other enthusiast forums besides this one, such as Bimmerforums, E46Fanatics, or ZHPMafia? You might be able to encourage more 2002-2005 owners on those forums to file complaints.

I completely agree with you. Nevertheless, NHTSA is quite skilled at sorting out the facts and are not to be fooled.

Originally Posted by edlvrt

Update...

Yesterday I received a letter from the NHTSA stating that there is not enough evidence of 2004 330s with defective headlights to warrant a safety investigation. So apparently there never was an investigation....

I am composing a letter in response to the one I received stating that the issue is not limited to 2004 330s but all E46s (1999-2006). I also want to stress to them that me driving 45 on the interstate at night is more of a safety concern than the tail lights, which have received the appropriate attention. If you want the name and mailing address so you can write as well, PM me.

Keep calling in, sending online complaints, and mailing letters. They are listening, but they need to hear from more people. Be sure to make note of any near misses or accidents due to your lack of visibility at night.

Thanks

I've checked NHTSA's Office of Defects Investigation (ODI) database; you're correct, no defect investigation was ever opened. They need to see more complaints in their consumer complaint database. It is perhaps worth mentioning that any consumer can officially petition NHTSA/ODI to open a safety investigation. There are preferred ways to do this other than an informal letter (the procedure can be Googled), and the assistance of a lawyer with experience in such matters is helpful but not necessary. Such an effort (petition) would be more effective with more evidence of a defect IMO. NHTSA has more information access, other than the complaint database to accumulate defect information:

1. They require the manufacturer to submit warranty data to them every quarter.
2. Require insurance companies to submit insurance claim data for certain components.
3. Requires the manufacturer to submit TSBs for component failures and "fixes."
4. Requires the manufacturer to submit data on foreign recalls for substantially similar equipment.

An investigation may be triggered if any of the above information sources single out a defect trend with a certain item of the vehicle.

I just ran across a very recent consumer petition from a Honda EV owner (private citizen), claiming a brake defect (and subsequent fatality). I was quite amazed at the thoroughness of NHTSA's investigation into the petitioner's request.

Geez....Now that I'm having to deal with the brake light issue I was about the possibility about having to deal with another issue that should've already been taken care of by BMW...I just went to double check my '03 325i and, as luck would have it, I have the Bosch frosted lenses, so for once, I don't have to worry about yet another retro-fix. Good luck to any of you who are having to deal w/this issue!

Originally Posted by G. P. Burdell

I understand your concern that this defect will drop off of NHTSA's radar screen. However, as one who partially funds NHTSA with my tax dollars, I would prefer to see the agency conduct an efficient investigation based on real data - that is, based on real complaints filed by affected 2002-2005 sedan owners. Exaggerating the scope of the defect by including four unaffected model years doesn't seem like a productive way to keep NHTSA's interest.

Have you posted your appeal to any other enthusiast forums besides this one, such as Bimmerforums, E46Fanatics, or ZHPMafia? You might be able to encourage more 2002-2005 owners on those forums to file complaints.

It was never my intent to try and mislead the NHTSA, and if I came across that way, I am sorry. I would not want anyone to submit false information to the NHTSA. From reading the message boards, it does indeed appear that the affected vehicles are 2002-2005 sedans. However, only BMW knows exactly which vehicles received which headlights.

When writing my post that you are commenting on, I remembered that there was an option on the NHTSA website where you could report your vehicle by chassis, ie E46 3 Series, and not list engine or year. My intention was to recommend that owners report in as broad of a selection as possible in hopes that the NHTSA would not discard the complaint at a select few.

I have posted on several other message boards. Many people have reported in that they have filed complaints. The only way this can progress to an investigation and possible recall is if affected owners makes themselves heard. Please help spread the word to any and all BMW message boards, friends, BMW meetings, etc, about the ability to report this defect.

I have recently completed a retrofit to E90 reflector bowls and I'm amazed with the light output. I am writing a letter in response to the one I received from the NHTSA and will include my cracked, burnt, transparent reflectors as an early Christmas present to the folks in DC.

Thanks to all who have reported. Keep em coming.

Ed

Originally Posted by edlvrt

It was never my intent to try and mislead the NHTSA, and if I came across that way, I am sorry. I would not want anyone to submit false information to the NHTSA. From reading the message boards, it does indeed appear that the affected vehicles are 2002-2005 sedans. However, only BMW knows exactly which vehicles received which headlights.

When writing my post that you are commenting on, I remembered that there was an option on the NHTSA website where you could report your vehicle by chassis, ie E46 3 Series, and not list engine or year. My intention was to recommend that owners report in as broad of a selection as possible in hopes that the NHTSA would not discard the complaint at a select few.

I have posted on several other message boards. Many people have reported in that they have filed complaints. The only way this can progress to an investigation and possible recall is if affected owners makes themselves heard. Please help spread the word to any and all BMW message boards, friends, BMW meetings, etc, about the ability to report this defect.

I have recently completed a retrofit to E90 reflector bowls and I'm amazed with the light output. I am writing a letter in response to the one I received from the NHTSA and will include my cracked, burnt, transparent reflectors as an early Christmas present to the folks in DC.

Thanks to all who have reported. Keep em coming.

Ed

The ZKW projectors were found in 2003-2005 sedans and tourings. Vast majority were in 2003-2004; there may have been some 2002 models with them, but I haven't come across one. They did switch back to AL in 2005, but I have seen a couple zkws get through. Unfortunately it's impossible to determine via VIN or option codes which cars got which headlights. Only BMW would know which cars got which.

With the proper equipment, it'd be quite easy to determine that the zkw headlamps in their failed state don't meet the standards set forth by fmvss 108. I don't know where to get such equipment though; it seems inspection shops don't bother measuring light output either.

Probably because no other vehicle has had a headlight issue like this? haha. And anyone who does have a defective ZKW unit may not even know as gradual change is hard to see unless compared against something that hasn't changed.