E46 ZKW Reflector Recall-Open NHTSA Investigation

Originally Posted by roverT

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.

I think it depends on where you live too. I live in the middle of nowhere pretty much, and we have very little street lighting. Other areas have enough street lighting that you can often get away without headlights at all.

IMO the fact that BMW updated the projectors from plastic to metal in the E90 is pretty strong evidence that BMW knows there was a problem.

Originally Posted by TerraPhantm

IMO the fact that BMW updated the projectors from plastic to metal in the E90 is pretty strong evidence that BMW knows there was a problem.

Also, ETK used to (and may still) state that certain replacement D2S bulbs are "not for ZKW."

will a non zkw work as a replacement?

Originally Posted by 450ac

will a non zkw work as a replacement?

OE headlights manufactured by AL are practically plug and play. Search here to find a wealth of information.

I just sent in my complaint. My headlights are just getting terrible. I live in the middle of nowhere and I almost get better lighting from my fog-lights that my headlights.

I'm seeing some of the ZKW complaints show up in NHTSA's complaint database. It's perhaps worthwhile to note that NHTSA's original investigation of the E46 tail light issue was initiated by a private citizen E46 owner...he submitted a petition to NHTSA and they accepted it:

http://wheels.blogs.nytimes.com/2011...ty-tail-lamps/

Here's a rundown on current recall activity on the car:

http://www.faqs.org/car/bmw-e46-2005/

Submitting a petition to NHTSA:

http://www.nhtsa.gov/Vehicle+Safety/...ampaigns.print

Infield a complaint several months ago and was never contacted in response. It would seem like this issue is a cut and dry case of a design flaw that creates a safety hazard and would therefore warrant a recall. My driver's side headlight has gotten so bad that you can see a brown haze in the projector lens when the light is on. The output is terrible.

Originally Posted by briangl92

Infield a complaint several months ago and was never contacted in response. It would seem like this issue is a cut and dry case of a design flaw that creates a safety hazard and would therefore warrant a recall. My driver's side headlight has gotten so bad that you can see a brown haze in the projector lens when the light is on. The output is terrible.

NHTSA won't respond to a complaint, but they should respond to a "petition." There should be sufficient details in a petition to give NHTSA something to "bite" on. Such details may include (name redacted) comments from this web sit, other web sites regarding the light problem and references to complaints already filed. NHTSA's main concern would be the safety hazards associated with the defect.

From NHTSA's web site on "petitions":

Any person may submit a petition requesting NHTSA to open an investigation into an alleged safety defect. After conducting a technical analysis of such a petition, ODI informs the petitioner whether it has been granted or denied. If the petition is granted, a defect investigation is opened. If the petition is denied, the reasons for the denial are published in the Federal Register. Similarly, a person may submit a petition requesting NHTSA to hold a hearing on whether a manufacturer has reasonably met its obligation to notify and/or remedy a safety defect or noncompliance with a Federal motor vehicle safety standard. If the petition is granted, a hearing is held to assess the matter and decide what corrective action should be taken. If the petition is denied, the reasons for the denial are published in the Federal Register.

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Aren't there any lawyers in here willing to do a little pro bono work? ;-)

Greetings from Sweden!

I can confirm that the ZKW issue exists also for European assemblies of E46 - 2003-2005 (ours was produced may 2003, first owner). In Sweden we have mandatory headlight usage (Daylight Running Lights) 24 h a day, so our ZKWs run out slightly faster. Also, replacing them is as costly as in the US, I got a quote for USD 3000 for booth sides. As we also have mandatory annual vehicle inspections (emissions and security), the headlights needs to be replaced every time you get your car fails the inspection.

Notes:
The AL assembly can be installed instead of the ZKW, one of the connectors is slightly differently placed, which means you have to stretch the cabling slightly, but you should not need to replace the cabling.. To my knowledge, only ZKW assemblies has reported the issue. My car is currently running with one headlight from each producer, no issues with the AL assembly.

A visible ZKW mark is located on the headlight glass, you do not need to lift the hood to validate assembly type. AL lights are not marked in the same way, so if you can't see the mark it is probably an AL assembly.

No recall has been announced for the Swedish market and BMW does not accept this as a warranty issue. Funny you should pay for extras to get really bad quality headlights!

Originally Posted by eborgelin

A visible ZKW mark is located on the headlight glass, you do not need to lift the hood to validate assembly type. AL lights are not marked in the same way, so if you can't see the mark it is probably an AL assembly.

Welcome to the forum, and thank you for letting us know that this problem is not confined to cars sold in the U.S.

One comment on the above: there has been discussion on this and other forums regarding interchangeability between AL, ZKW and possibly other brands of headlight covers. Consequently, reading the markings on the covers should not be considered a reliable method of identifying the headlight manufacturer.

We have found two ways to identify, definitively, the headlight manufacturer. One way is to look for the manufacturer's label on the top side of the assembly. The label is often hidden by the metal headlight support. The second way is to look at the projector lens; if it has a frosted appearance and a horizontal line milled across it, it's an AL projector. If the lens is crystal clear and has no line, then it's a ZKW projector.

Note: I have only worked with U.S.-spec bi-xenon headlights, so I have not been able to confirm that the Euro-spec projector lenses have the same identifying features described above. Eborgelin, since you are running one ZKW headlight and one AL headlight on your car, please let us know if the projector lenses look different.

Originally Posted by G. P. Burdell

Welcome to the forum, and thank you for letting us know that this problem is not confined to cars sold in the U.S.

One comment on the above: there has been discussion on this and other forums regarding interchangeability between AL, ZKW and possibly other brands of headlight covers. Consequently, reading the markings on the covers should not be considered a reliable method of identifying the headlight manufacturer.

We have found two ways to identify, definitively, the headlight manufacturer. One way is to look for the manufacturer's label on the top side of the assembly. The label is often hidden by the metal headlight support. The second way is to look at the projector lens; if it has a frosted appearance and a horizontal line milled across it, it's an AL projector. If the lens is crystal clear and has no line, then it's a ZKW projector.

Note: I have only worked with U.S.-spec bi-xenon headlights, so I have not been able to confirm that the Euro-spec projector lenses have the same identifying features described above. Eborgelin, since you are running one ZKW headlight and one AL headlight on your car, please let us know if the projector lenses look different.

I believe all Euro headlights have clear lenses w/ no line.

On the ZKW headlights, all the plugs go right into the back of the headlight; the male connectors are molded right into the plastic housing. On the ALs, the low beam and bixenon connectors go directly to the ballast, and the high beam connector connects to a bulb holder behind the highbeam bulb.

I am surprised that there still isn't a recall to date. As I mentioned above, the fact that the E90 ZKW bowls are pretty much the same design, except made of metal, should indicate that ZKW became aware of the flaw and fixed it for newer models.

Same problem here, I submitted my complaint