Front strut spacers and bumper height requirements

Dick Steinkamp

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What I generally hear is that our E9s and E3s have front strut spacers in order to meet DOT bumper height requirements. I got to thinking about the other late 60s early 70s cars I've owned and the fact that some had pretty low bumpers. I looked up the history of US bumper height laws.


The first bumper requirements were implemented in the fall of 1972 for the 1973 model year cars. They did not deal with bumper height, only minimizing damage during a low speed impact...

"In October 1972, the U.S. Congress enacted the Motor Vehicle Information and Cost Saving Act (MVICS), which required NHTSA to issue a bumper standard that yields the "maximum feasible reduction of cost to the public and to the consumer""

The first law that standardized bumper height applied to the 1974 model year cars...

"The standards were further tightened for the 1974 model year passenger cars, with standardized height front and rear bumpers..."


My conclusion is that the spacers in our cars produced through the 73 MY are not there to meet a US bumper height requirement. They are there for some other reason. Ideas?

Even after the 73 MY, my guess is that the prior bumper height of E9s and E3s would have likely met the new bumper height standard and would not have required additional strut spacing. Of course they would still need to be modified (diving boards/picnic tables) to comply with the other requirements of the 74 MY bumper standard.
 
The other reason often cited is headlight height I think.
This is the only thing I could find on headlight height requirements. Even these may not have been law in the 60s and 70s. In any case, I think our cars meet them....

Headlight Height Requirements
Headlight heights are always measured from ground level to the center of the lowest bulb on a vehicle's headlight assembly. The follow states mandate that headlight height be between 24 and 54 inches from ground level: Alaska, Arkansas, Washington DC, Indiana, Kansas, Louisiana, Maine, New Mexico, New York, Oklahoma, Oregon and Texas. Colorado mandates a maximum light height (44 inches), but not a minimum.

 
Ahhh from the same people who insist brake fluid have a golden color, thus the end of ATE Blue in the US.
 
The BMW internal memo to dealers cited the headlight height as the reason
Can you post the memo, Steve? It would be interesting to see the date (hopefully the cut in date), and any other additional info like the minimum height required by the US and by which agency.
 
Excellent! Thanks, Steve!

Memo is dated March 31, 1971, so it is likely that by my 7/71 Bavaria that they would already be installing the 20mm spacer at the factory. I would imagine there are some early E3s and E9s in the US that were never retrofitted with the spacers.

A bonus is that the memo includes instructions . :)
 
What seems so strange is that the memo states owners are having trouble with the correct height. Was this in states with yearly safety inspections? Once built and sold how can FMVSS issues be retrospectively applied? It has never worked that way.
 
A little strange that it only applies to 6 cylinder cars (E3, E9). I wouldn't think the 1600/2002 would have higher headlights than the E3/E9.
 
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