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Subaru Tried to Avoid an Impreza Headlight Recall and the NHTSA Said No

The company will have to replace headlight assemblies in almost 190,000 sedans and hatchbacks built between 2016 and 2019.

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Subaru will replace both front headlight assemblies in all model year 2016 to 2019 Impreza sedans and hatchbacks, totaling almost 190,000 vehicles. That’s 380,000 new headlights, at a time when the supply chains for a variety of components — including lighting — are not exactly running optimally.

This saga goes back to the summer of 2019, when an NHTSA investigation determined the compact’s left front halogen assembly was underperforming, failing to properly light the road and posing a potential glare for oncoming motorists.


Subaru addressed this by replacing mold inserts for left-hand low beam reflectors. A few months later, the NHTSA found that the side reflex reflectors of both assemblies were also defective as manufactured, and that left low beam reflectors failing, too. From the department’s Safety Recall Report:

During the manufacturing process, a side reflex reflector part was caught in the mold resulting in damage to the mold. Some side reflex reflectors produced after mold damage may have diminished reflective performance. At a later date, the mold used in production of the halogen low beam headlamp reflector was worn to a point where production parts may no longer meet certain data point performance requirements.


The upshot of all of this is that Subaru is now on the hook to rip out and replace assemblies in 188,397 halogen-equipped Imprezas across four model years. (LED-equipped models are not affected.) However, the NHTSA’s report states that Subaru initially attempted to avoid this, sending the department a Petition of Decision of Inconsequential Noncompliance — essentially, that the company didn’t deem the problem severe enough to warrant a recall. Obviously, we now know how successful that was.

Ironically, General Motors recently tried to avoid a Terrain headlight recall the very same way, with an “Inconsequential” petition. The NHTSA didn’t take kindly to that one either and denied GM’s request, much like it denied Subaru’s. That campaign was considerably worse for the American automaker, as it covered roughly 727,000 vehicles ranging from 2010 to 2019.

Good headlights are important — both so drivers can see where they’re headed, and so the rest of us aren’t blinded when we pass them in the opposite direction. Carmakers really shouldn’t try to dismiss lighting complaints! Thankfully the NHTSA didn’t let this one skate by. Subaru plans to notify relevant owners before mid-October, but if you’d like to check your car’s status now, you can do so using the NHTSA’s VIN lookup tool.