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E46 ZKW Reflector Recall-Open NHTSA Investigation

136K views 95 replies 41 participants last post by  Joanna@MaXpeedingRods 
#1 ·
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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#59 ·
ZKW Reflector

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. :mad: Funny you should pay for extras to get really bad quality headlights!
 
#60 ·
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.
 
#61 · (Edited)
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.
 
#67 ·
Some in here are surprised that there hasn't been a (NHTSA) recall, but how many have actually submitted a complaint to NHTSA's complaint database? This is necessary to capture NHTSA's attention...particularly if the lighting issue reduces "luminosity" or the intended brightness of the lights (Ref: Federal Motor Vehicle Safety Standard - FMVSS 108).

FMVSS 108 is a complex fmvss, but includes min. "luminosity" standards as well. If this "issue" puts the lights "outside" of federal luminosity standards? You may have a case.

No lawyers in this group? A "petition" to NHTSA for this issue does not involve rocket science, and with some effort to report the facts, will put NHTSA's back to the wall as it will become a public record, and NHTSA will have to investigate and respond. Nobody's up to writing a petition? You have nothing to lose.
 
#68 ·
Shocked by this as well. I don't understand why nhtsa hasn't investigated though. Autoblog reported this week the nhtsa is investigating 2008-2009 c class sedans for tail lights that melted or smoldered and may not fully illuminate properly after 21 complaints. There are about 100 complaints on the nhtsa site for 2004 models alone and we still haven't gotten an investigation.

Obviously a petition is the only way we will get this issue resolved.

Sent from my Galaxy Nexus using BimmerApp mobile app
 
#70 ·
You guys would be better off retro-fitting no ZKW bowls than waiting for a recall that will never come. I put Bosch projectors into my ZKW housings and swapped the ZKW lenses for the bosch lenses. It has been awesome for 1.5 years now. I did a thread on here somewhere.
 
#73 ·
Did you register a complaint with NHTSA on their web site? No? This is the only way (except for a brave individual who'll submit a petition) that ANYTHING will get moving.
 
#75 ·
It's 2014. I have 2005 330i and just thought I had aging eyes. I am so mad about this light/reflector issue that I want to scream. $3200. I emailed BMW and they told me to go get a diagnosis. Well that was $173. I drive in the N GA Mnts at night 2x a week and it is scary. Should I still complain?
 
#76 ·
Sorry you blew $173. They knew exactly what was wrong and just wanted you to go away. If you want it fixed the best thing to do is either send them away to light weeks or order the kit and do it yourself. I retrofitted mine about 6 months ago and the difference is like night and day. I don't remember what it cost but it's a few hundred dollars to do it yourself.
 
#78 ·
I actually ended up going through the retrofit source not lightwerkz. It was like $225 I believe for the kit. Here is a link to the DIY. You just need to be patient and go slow. You can't order any of the plastic bits if you break anything because BMW only sells it as a full unit. I also replaced the lense covers and gaskets as well, which wasn't cheap, but my lenses were shot and were fogging up. That doubles the price of the project but it made a world of difference. ANyway good luck!

http://www.theretrofitsource.com/diy-installation-guides.html
 
#80 ·
Not one person is willing or has the time to send a petition to NHTSA over this defect? Not one lawyer in the group?

The petition process is simple and straightforward (my previous posts). The worst outcome? NHTSA will analyze the complaint databaseand other sources of information...and perhaps deny the petition. Even this doesn't necessarily mean the end of it.

This is why it's important that EVERY owner submit his/her complaint to the safercar.gov complaint database including any safey implications (actually experienced) associated with the defect. Don't exaggerate your personal experience.

In the meantime, everone keep their receipts.
 
#82 ·
I reported my complaint today! This is all great info. I have to get it fixed. I drive in the n ga Mnts some nights. My click n pass is bright!!! Lights up the whole road. :cry:
filing a complaint with NHTSA in 'safercar.gov' only takes a few minutes. You'll see the section: 'Complaints and Defects' for those who have experienced the defect.

Go for it. No personal information is asked for and NHTSA always redacts any personal information (car VIN for example).
 
#84 ·
#90 ·
Hey guys, so I've been debating about what to do with my headlights for months. Do I order from umnitza and do angel eyes and fxr projectors or so I retrofit. Well I am pinched for cash currently but the light output irritates me to the core. So I think I am going to do a retrofit.

https://www.retrofitlab.com/bmw-3-e46-zkw-oem-md2s-1.html

This is the one I'm thinking, doesn't look too tough and has good reviews. Plus the price is right. I thought I would reach out and ask if anyone here has used this one specifically or had another recommendation..help! Thanks guys
 
#92 ·
There isn't a recall yet. The thread starter's goal was to encourage affected owners to file a report with NHTSA in the hopes of starting an investigation, which could lead to a recall. The problem is with bi-xenon headlights manufactured by ZKW for sedans and wagons.

How old are the bulbs? All xenon bulbs lose output as they age. Have you had any suspension work done recently? The auto-leveling sensors can become damaged and cause the lights to be misaligned. Can you see any burn marks or light leaks when you open the back covers on the headlight assemblies?
 
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