Tesla Wants U.S. Headlight Rules to Catch Up With Its Cars

Tesla is urging U.S. safety regulators to rethink how vehicle headlights are tested, arguing that rules built around bulbs and fixed high and low beams need to account for cameras, software and lights that change their shape in real time.

In a November 9 letter to National Highway Traffic Safety Administration (NHTSA) Administrator Jonathan Morrison, Tesla backed plans to modernize Federal Motor Vehicle Safety Standard No. 108. But it also warned that automakers are getting too little representation on the proposed advisory committee.

“Tesla designs and integrates exterior lighting as part of a software-defined vehicle,” wrote Suraj Nagaraj, Tesla’s senior director of safety and homologation engineering.

The company’s argument goes beyond brighter lights. As its recent adaptive-headlights demo shows, matrix LEDs can dim individual sections around other road users while keeping the rest of the road illuminated. Tesla says its cameras identify vehicles, pedestrians, cyclists and road geometry, helping software decide where light should go.

That makes adaptive lighting a matter of understanding the driving scene, Tesla argues, rather than simply reacting to a light sensor. It wants testing to consider how quickly and accurately a vehicle reshapes its beams across different weather conditions and road layouts.

“Glare, upper- and lower-beam photometry, aim and mounting height, and adaptive-beam performance cannot be resolved by lamp-level laboratory points alone,” the letter states.

Tesla also objects to reserving just two of the proposed 18 stakeholder seats for individual automakers, compared with four for lighting manufacturers or retailers and four for manufacturing associations. It wants more automaker seats and a larger committee, saying car companies remain responsible for integrating the lights and ensuring vehicle safety.

NHTSA’s notice covers glare, headlamp aim and height, testing methods and alignment with international standards. Any consensus recommendations would feed into a proposed rule for public comment, so this letter does not mean new requirements have been adopted.

For owners, adaptive headlights are already available on compatible U.S. and Canadian Teslas through the 2025.14 update. This push concerns future standards, not a newly announced software rollout.

Have adaptive headlights improved your night driving, or is glare from other vehicles still the bigger problem?