Content
Abstract:
The widespread adoption of LED headlights and lithium batteries by commercial vehicles as part of import substitution is creating unresolved legal conflicts. The essence of the conflict: replacing a halogen bulb with an LED in a standard headlight inevitably violates the boundary between light and shadow, which, without recertification, directly violates traffic safety requirements. At the same time, environmental regulations require the disposal of failed LED devices as hazardous waste, without providing a viable infrastructure.Carriers are faced with a dilemma: bear the costs of a certified headlight, a waste certificate, and a licensee, or violate regulations, risking fines and business interruption. The goal is to identify legal conflicts and propose changes to legislation (de lege ferenda) and develop an algorithm for the legal write-off of LED headlights for commercial vehicles.Methods: formal legal, systemic interpretation, comparative legal, legal modelling, economic analysis of law, analysis of law enforcement practice, legal forecasting.Scientific novelty: for the first time, the legal problems of freight carriers in the transition to energy-saving lighting technology have been systematized with an assessment of economic risks and substantiation of foreign experience (EU, Germany).Practical significance: the results can be used in preparing amendments to TR CU 018/2011, laws No. 89-FZ and No. 40-FZ, and as a checklist for legal services.Key findings: A conflict was identified between the ban on aftermarket lighting and the requirement to dispose of used LED headlights as Class III – IV hazardous waste; a typical violation scenario was established; and five legislative amendments were proposed.
References:
1. Egiazarov, V.A. Transport law: textbook [Transportnoye pravo: uchebnik], 8th ed., supplemented and revised // M.: Yustitsinform, 2015. 2. Broslavsky, L.I. Problems of improving waste legislation: extended producer responsibility [Problemy sovershenstvovaniya zakonodatel'stva ob otkhodakh: rasshirennaya otvetstvennost' proizvoditelya] // Environmental Law, 2024, # 6, pp. 13–20. 3. Zhmatov, D.V., Gorkin, V.P., Pakhomova, E.E. Features of the application of energy-efficient lighting technologies in vehicles [Osobennosti primeneniya energoeffektivnykh tekhnologiy osveshcheniya na transportnykh sredstvakh] // Energy safety and energy saving, 2016, May-June, # 3 (69), pp. 16–20. 4. Gusev, V.F. Features of diagnostics and adjustment of car headlights [Osobennosti diagnostiki i regulirovki avtomobil'nykh far] // Technical and technological problems of service, 2012, # 1(19), pp. 13–19. 5. Pakhomova, E.E., Gorkin, V.P., Yakunov, D.M. Design features of automobile headlights on LEDs [] // Izvestiya Moscow State Technical University MAMI, 2014, # 2 (20), Vol. 1, pp. 51–54. 6. ACEA: The Automotive Regulatory Guide 2023 / Brussels, 2023, 311 p. URL: https://www.acea.auto/publication/automotive-regulatory-guide-2023/ (date of accesses 21.04.2026). 7. Böttcher, B. LED Retrofit Lamps as Replacement for Incandescent Lamps: Update/Extension of UNECE Rules, 2018, 10 p. (photometric measurements). URL: https://drive.google.com/file/d/1mlkcD4NgzvcH7sqDW9RScDt8FfNZUVTQ (date of accesses 05.05.2026).
Keywords
- LED headlights
- commercial vehicles
- legal conflicts
- waste disposal
- extended producer responsibility
- LED retrofit
- administrative liability
- insurance recourse
- technical regulation of the Customs Union 018/2011
- energy saving lighting devices
Recommended articles
Energy Saving in the Sphere of State Public Interests. L&E 27 (№1. 2019)
Optimisation of Illuminance of Municipal Facilities and Protection of Retail Power Consumers: Interdependence of Processes. L&E 27 (5) 2019
Efficiency in the Choice of Power Service Contract as Way of Financing Power Service Activities. L&E 26 (1) 2018