Interpretation ID: aiam4657
Vice President Product Compliance Service and Parts Mercedes-Benz of North America
Inc. P.O. Box 350 Montvale
NJ 07645-0350;
Dear Mr. Faber: This is in reply to your letter of August 9, l989, wit respect to the interpretation of the word 'headlamp' as it appears in paragraph S7.2 of Motor Vehicle Safety Standard No. 108. In pertinent part, this paragraph specifies that certain markings shall be placed on the lens of each headlamp, with 'each headlamp' to be marked with the voltage and part or trade number. Noting that 'headlamp' is not a defined term but 'replaceable bulb headlamp' is, you have asked for confirmation that marking the lens, the reflector, or the light source with the voltage would be in compliance with paragraph S7.2. The agency intends that the voltage be indicated on the exterior of the headlamp. If the manufacturer does not wish to put it on the lens, Standard No. 108 will permit, as of December 1, l989, voltage marking to be on an exterior part of the headlamp body, but not on the light source. I hope that this answers your question. Sincerely Stephen P. Wood Acting Chief Counsel /;