Interpretation ID: 18558.ztv

Mr. Jim Ashdown
E & D Manager
Magnetti Marelli UK Ltd.
Lighting Division
Walkmill Lane, Cannock
Staffordshire WS11 3LP
England

FAX 9-0111543466325

Dear Mr. Ashdown:

This is in reply to your fax of August 6, 1998, to Taylor Vinson of this Office. Because of the need to coordinate interpretations of Federal motor vehicle safety standards with other Offices of this agency, we were unable to respond by "return fax" before now.

You have two questions and they relate to Federal Motor Vehicle Safety Standard No. 108. You ask for confirmation that "paragraph S.7.8.5.2.C is the correct section for tamper proof V HAD systems." We confirm your understanding. Paragraph S7.8.5.2(c) requires that headlamps with VHADs manufactured for use on motor vehicles manufactured on or after September 1, 1998, shall be manufactured with their calibration permanently fixed by the headlamp manufacturer.

Your second questions is whether there is "a requirement now for optical centre markings on rearlamps similar to S.7.8.5.3.f on headlamps." There is no such requirement. Paragraph S7.8.5.3(f) requires such markings only on headlamps. There is no requirement in Standard No. 108 that the optical center be marked on any lamp other than a headlamp.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.9/22/98