Interpretation ID: 1983-3.20

TYPE: INTERPRETATION-NHTSA

DATE: 11/17/83

FROM: FRANK BERNDT -- NHTSA CHIEF COUNSEL

TO: PEKKA SUURONEN -- PRODUCT DEVELOPMENT MANAGER RACEMARK INTERNATIONAL, INC.

TITLE: NOA - 30

ATTACHMT: LETTER DATED 07/27/83 FROM PEKKA SUURONEN TO NHTSA

TEXT: Dear Mr. Suuronen:

This is in reply to your letters of July 27, 1983, and October 6, 1983, asking whether a sealed headlamp with "replaceable European H4 bulb," or "Ford bulb (6 standard sizes)" are considered "legal," (like Cibie BOBI) "provided it meets with all the applicable SAE standards."

Cibie certifies that its "BOBI" headlamp complies with all applicable Federal motor vehicle safety standards, pursuant to Section 114 of the National Traffic and Motor Vehicle Safety Act. Thus far, the National Highway Traffic Safety Administration has not contested that certification.

We do not understand your reference to the Ford bulb in "6 standard sizes." The only size of that bulb that may be used in the new replaceable bulb headlamp systems is the one specified in the recent amendment to Standard No. 108. However, Volkswagen has petitioned for rulemaking to allow the H4 bulb.

Sincerely,