Start with the approval route, then verify the exact product
Before comparing price, lumen output or cooling design, establish what approval route the exact SKU relies on. A category specification, product approval, compatibility list and R10 EMC certificate answer different questions.
The first sourcing question is therefore not “How bright is it?” but “What exact approval evidence supports this exact product in the market where I plan to sell it?”
The 12-point LEDr sourcing checklist
- Define the SKU. Record commercial reference, regulatory type, manufacturer, hardware revision and production site.
- Verify category status. Check current official R.E.5 material and adopted amendments.
- Obtain exact product approval. Request the complete approval communication and relevant extensions.
- Decode the marking. Match the physical sample to the regulation and approval record.
- Separate approval objects. Keep R37 light-source approval, R10 EMC and headlamp-level approvals distinct.
- Confirm application scope. Check the corresponding light-source category, lamp function or national positive list.
- Control accessories. Record every required adapter, reference ring, electronics module and rear cap.
- Review optical evidence. Distinguish source-level tests from complete headlamp beam photometry.
- Review thermal and electrical evidence. Check stabilized conditions, not only cold or open-bench marketing figures.
- Audit production consistency. Confirm how mass production remains connected to the approved type.
- Freeze change control. Require notification before changes to LEDs, drivers, cooling, caps, markings or factories.
- Approve market wording. Map every public claim to the exact evidence, scope and review date.
A missing item should become a named condition before approval, not something filled with a supplier's broad assurance.
EB-H11 shows what a traceable evidence chain looks like
The AZMK EB-H11 is identified as an H11 LED replacement light source under UN Regulation No. 37, approval reference E8*37R03/49*0106*00. The associated technical report is CS008-26-TAC through TÜV SÜD Czech.
The same product configuration has separate UN R10 EMC approval E8*10R06/03*17720*00 with technical report CS020-25-TAC. This is the pattern buyers should expect: exact type, exact regulation, traceable document and a clear statement of what each document proves.
The public product reference used in this checklist is EB-H11.
Keep every measurement tied to the object that was actually tested
The EB-H11 R37 report records a Configuration-2 bi-directional source and compliance testing for emitting-area position and dimensions, luminous flux, normalized intensity, electrical and photometric characteristics, colour and cap temperature.
At 13.2 V, five tested samples averaged 1,454 lm and 14.59 W after one minute, and 1,409 lm and 14.50 W after 30 minutes. These values belong to the tested EB type; they should not be transferred to another SKU or turned into a general statement that every legal LED replacement should outperform halogen on raw lumens.
The same report records cap temperatures from 44.2°C to 48.2°C after the specified test period. That supports the approval test result under those conditions, not long-term lifetime, lumen maintenance or thermal-cycling durability.
Source-level normalized-intensity and emitting-area tests are not a complete headlamp beam-pattern approval under R112 or R149.
For national positive-list routes, verify the complete application
No adopted harmonized Group 5 H7 or H4 LED replacement category sheet was identified in the reviewed R.E.5 material as of 21 July 2026. Specific products can still have national or application-specific approvals in selected markets.
For those routes, record vehicle make and model, production period, headlamp approval number, light function, exact LED product and required accessories. Model name alone may not be enough because the same vehicle can use different headlamps.
Public compatibility lists also show how adapters, electronics modules and replacement caps can be tied to specific applications. A list for one approval holder does not prove coverage for another supplier.
Approve a controlled production type, not one golden sample
Mass production introduces ordinary risks: LED packages change, drivers are substituted, cooling parts are revised, molds are repaired and markings move between suppliers.
Buyers should identify approval-sensitive characteristics and require advance change notification. The supplier should explain which changes require internal verification, an approval extension or a new approval.
Conformity-of-production records should connect shipped batches to the approved type. A quality-system certificate alone does not prove that the exact LEDr product remains unchanged.
Build one country and application matrix before publishing road-use claims
Record destination country, approval route, exact product, application, required documents and approved wording. For a positive-list route, add vehicle/headlamp identifiers and controlled accessories.
UN R37 type-approved H11 LED replacement light source for 12 V applications, subject to the approved product configuration and applicable market requirements.
Do not generalize one national approval to every European market or guarantee a periodic-inspection result.
Turn the checklist into an RFQ and decision record
Require suppliers to complete structured fields for product identity, category basis, approval holder, approval number, manufacturing site, SKU, marking, destination markets, application scope, required accessories and document revision.
Record one of three decisions: approved for a defined claim, conditional pending named evidence, or rejected because a material identity or approval gap remains.
Put advance change notification into the supply agreement. This lets brands and importers compare suppliers on approval traceability, optical control, thermal evidence, OEM/ODM change management and production consistency instead of headline lumen claims alone.
Sourcing questions
What is the first buyer question?
Ask what approval route covers the exact product and request the complete evidence chain.
Should brightness decide sourcing?
No. Approval scope, optical control, thermal stability and production consistency should be established first.
Can R10 replace R37?
No. R10 is electromagnetic-compatibility evidence.
What should happen when a component changes?
Freeze the affected claim until the approval holder assesses whether the change remains within the approved type.
Official and approval-holder sources
- UNECE, UN Regulation No. 37
- UNECE, Consolidated Resolution R.E.5 register
- UNECE, UN Regulation No. 10 register
- OSRAM, public compatibility-list example
Product-specific approval references above 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.