Mr. J. Yoshimoto
Deputy General Manager
Technical Administration Department
Koito Mfg. Co. Ltd.
Shizuoka Works
500, Kitawaki
Shimizu-Shi, Shizuoka-Ken

Dear Mr. Yoshimoto:

We have received your letter of February 9, 1996, asking for an interpretation of Motor Vehicle Safety Standard No. 108 and 49 CFR Part 564.

As you noted, the dimensional and specification information on HB Types of replaceable headlamp bulbs and their associated Figures were recently transferred from Standard No. 108 to Docket No. 93-11, established by Part 564. Note 2 to Figure 23-1 states that "It must be possible to insert the light source into a cylinder of diameter "s" concentric with the reference axis and limited at one end by a plane parallel to and 20 mm distant from the reference plane and at the other end by a hemisphere of radius s/2"

You asked whether the light shield is allowed to be located in the hatched area shown in Figure 23-1 and its note (2). You believe that the light shield may be located in the hatched area because the area is specified in order to allow room for the H4 yellow light source permitted by ECE REg. No. 37. However, there is no reason to allow room because yellow headlamps are not permitted under Standard No. 108.

Under Figure 23-1 and Note 2, no light shield may be located in the hatched area; therefore, we cannot agree with your interpretation. If Koito wishes to file a modified drawing to Docket 93-11 permitting installation of a light shield in the hatched area it may do so. However, in accordance with Sec. 564.5(d)(3) and (4), the changed drawing must be accompanied by

statements that the use of the light source as modified will not create a noncompliance with any requirement of Standard No. 108 when used to replace an unmodified light source in a headlamp certified by its manufacturer as conforming to Standard No. 108, and information demonstrating that the modification will not adversely affect interchangeability with the original light source.

If you have any questions, you may refer them to Taylor Vinson of this Office (202-366-5263).


Samuel J. Dubbin Chief Counsel

ref:108 d:4/2/96