Robert Bosch GmbH
Dear Herr Spingler:
We have received your FAX of February 15, 1995, asking whether a proposed design "for a lens-reflector-joint can be considered as conforming to the appropriate definition in FMVSS 108."
The agency does not advise manufacturers whether particular designs are regarded as "conforming." That determination is to be made by the manufacturer in certifying that its product conforms to all applicable Federal Motor Vehicle Safety Standards. However, we can provide you with an interpretive guideline. Section S4 defines a "replaceable bulb headlamp" as a headlamp "comprising a bonded lens reflector assembly and one or two replaceable light sources." The intent of the definition was that the lens and reflector assembly be an indivisible unit upon manufacture of the headlamp. This means that, if a lens is broken, the entire lens reflector assembly must be replaced. If your design is such that the lens cannot be removed from the reflector assembly for replacement, it would appear to meet the definition in S4.
As you are well aware, NHTSA granted your company's petition for rulemaking, and, in November 1994, proposed an amendment of the definition of "replaceable bulb headlamp" that would allow a replaceable lens if the headlamp incorporates a vehicle headlamp aiming device conforming to S220.127.116.11. Comments were due on this proposal February 21, 1995. In due course, after review of the comments, NHTSA will decide whether it will pursue further rulemaking or terminate the rulemaking action.
Philip R. Recht Chief Counsel ref:108 d:3/8/95