H11 LEDr is a regulated category, not a marketing synonym
An H11 LED replacement light source can be approved under the UN R37 and R.E.5 framework when the exact manufactured type meets the applicable category requirements and receives type approval. That is different from an aftermarket LED bulb that merely fits an H11 connector.
The regulated route controls far more than physical fit. It addresses emitting geometry, photometric behavior, electrical characteristics, thermal conditions, mechanical construction, marking and production conformity. For the wider category picture, see ECE R37 LEDr Status in 2026.
Keep H11, LEDr, R37 and R.E.5 separate
H11 is the category designation. LEDr describes an LED replacement light-source category in this regulatory context. UN Regulation No. 37 provides the type-approval framework. R.E.5 contains the category specifications used by the light-source regulations.
R.E.5 answers what the H11 LED replacement category requires. UN R37 governs how an exact product type is approved. The approval communication identifies the approved product and holder, while the physical marking connects the shipped item to that record. A category-level comparison is available in H11, H8, H16 and HB4 LEDr Categories Explained.
H11 LEDr existed before the 2024 Configuration-2 amendment
The H11 LED replacement category path was established before the 2024 amendment. ECE/TRANS/WP.29/2024/156 amended the H11 LED replacement sheets to add Configuration-2 details for a bi-directional emitting arrangement.
It is therefore inaccurate to say H11 LEDr first became possible only in 2024, and equally inaccurate to assume that any two-sided H11 LED automatically satisfies Configuration-2.
What Configuration-2 changes, and what it does not prove
Configuration-2 addresses a bi-directional emitting arrangement. The category requirements control relationships between the emitting surfaces, reference geometry and photometric behavior so the replacement source can operate within a standardized light-source concept.
Visual similarity is not approval evidence. Chip size, emitting-area position, substrate thickness, mechanical reference, cap keying, electrical behavior and thermal operation can all affect the result.
EB-H11 provides a real H11 R37 approval chain
The AZMK EB-H11 is identified in an H11 LED replacement type approval under UN Regulation No. 37. The approval reference is E8*37R03/49*0106*00, issued under Czech Republic approval authority code E8. The associated technical report is CS008-26-TAC through TÜV SÜD Czech.
The public product reference used in this article is EB-H11. The approved product is a 12 V H11 LED replacement light source with a 15 W rated value; the technical information includes a 17 W maximum wattage figure. The report identifies a Configuration-2 bi-directional design.
What the EB-H11 technical report shows
The R37 report records compliance for the position and dimensions of the light-emitting area, maximum source outline, luminous-flux requirements, normalized-intensity requirements, electrical and photometric characteristics, white chromaticity, UV-related provisions and cap temperature.
At 13.2 V, the five tested samples averaged 14.59 W and 1,454 lm after one minute, and 14.50 W and 1,409 lm after 30 minutes. The category luminous-flux target shown in the report is 1,350 lm ±10 percent. The point is not “maximum brightness”; it is that the tested output remained within the regulated H11 LED replacement range.
The measured “e” values across five samples were 24.97 to 25.04 mm against the specified 25.0 ±0.1 mm range. The measured “f” values were 4.47 to 4.51 mm against the specified 4.5 ±0.1 mm range.
These results support compliance with the applicable source-level geometry and photometric requirements. They do not prove “perfect 1:1 halogen focus” in every headlamp and should not be presented as a complete R112 or R149 headlamp beam-pattern approval.
The report also records 30-minute cap temperatures of 44.2°C to 48.2°C across the five samples. This is approval-test evidence under the stated conditions, not a long-term lifetime or lumen-maintenance claim.
UN R10 EMC approval is useful, but it is not H11 light-source approval
The EB configuration also has UN R10 electromagnetic-compatibility approval E8*10R06/03*17720*00, with technical report CS020-25-TAC. The report records passing results for broadband and narrowband electromagnetic interference, radiated immunity, transient immunity and conducted disturbances.
That evidence supports EMC for the tested configuration. It does not replace UN R37 light-source approval.
Keep the public claim inside the approval boundary
UN R37 type-approved H11 LED replacement light source for 12 V applications, subject to the approved product configuration and applicable market requirements.
This is safer than “approved for all 12 V vehicles,” which can imply universal compatibility or legality regardless of lamp function, product configuration or destination market.
What a buyer should request for an H11 LEDr product
- The complete UN R37 approval communication.
- The approval holder, exact type, category and approval number.
- A physical production sample with matching marking.
- Installation information and any controlled additional electronics.
- Separate R10 evidence where EMC is claimed.
- Production-change controls linking later shipments to the approved type.
- Market wording that preserves applicable recognition and installation conditions.
H11 LEDr questions
Does H11 LEDr mean every H11 LED bulb is street legal?
No. The exact product must have matching approval evidence and be used within the approved configuration and applicable market requirements.
What did the 2024 amendment change?
It added Configuration-2 details for a bi-directional H11 LED replacement arrangement.
Is an R10 E-mark enough?
No. R10 concerns electromagnetic compatibility.
Does the approval report prove long-term lifetime?
No. Long-term lifetime and lumen-maintenance claims require separate evidence.
Official sources
- UNECE, UN Regulation No. 37
- UNECE, Consolidated Resolution R.E.5 register
- ECE/TRANS/WP.29/2024/156
- UNECE, UN Regulation No. 10 register
Product-specific approval references were checked against the approval communications and technical reports.
Jack Liu
Jack Liu has worked in automotive LED lighting since 2011 and began designing LED automotive headlight products in 2015. Since 2017, he has concentrated on automotive lighting regulations, particularly LED replacement light sources (LEDr), approval requirements, regulatory definitions, and how product design and optical performance affect legal compliance. Drawing on hands-on product development experience and research into official UNECE and other regulatory documents, he writes to make complex automotive lighting rules clearer and more practical for manufacturers, brands, importers and technical teams.