ADR 77/00 is the applicable ADR because the vehicle is fitted with gas discharge headlamps for low and high beam. The halogens are described by LR as fill-in lamps which would only be required under ADR 77/00 if the gas disharge lamps don't provide the mandatory light to the sides (there are 2 measurement points on each side of the lights). I do not have measuring equipment to determine if the bi-xenons alone provide side lighting that satisfies the requirements although my shed wall test suggests that they do not. If they do not then the headlamps do not comply with ADR 77/00 because the fill-in lights must be on the same horizontal plane as the low-beam horizontal cut-off line as described/defined in ADR 77/00. If the bi-xenons themselves provide the necessary side light (and necessary forward light at 75 metres which they seem to easily provide) then there is no light output requirement for the halogens.
I am intrigued that there is no E-mark for the halogens on the light assembly. The bi-xenon E-mark (its a single light source approval number) is on the globe holder and the E-mark for the blinker is on the assembly adjacent to the blinker globe. This suggests that either the bi-xenon doesn't require the halogen or the halogen+bi-xenon combination never obtained E approval, but it wouldn't have passed due to being possum spotters!
I have not received any response from my 3rd June inquiry to the NSW RTA for an update on their investigations. My information was going to be passed to the Safer Vehicles dept for investigation.
Edit: I would like to see how LR would explain the vastly different high-beam light patterns between the D3 and D4 lights.
MY21.5 L405 D350 Vogue SE with 19s. Produce LLAMS for LR/RR, Jeep GC/Dodge Ram
VK2HFG and APRS W1 digi, RTK base station using LoRa
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