International Regulatory Affairs Manager
34, rue St.-Andre
93012 Bobigny cedex
Dear M. Dorleans:
We have received your letter of March 19, 1996, asking for an interpretation of paragraphs S7.2(a) and S7.5(g) of Motor Vehicle Safety Standard No. 108. These paragraphs require that lenses of replaceable bulb headlamps be marked with the DOT symbol and the HB-type of light source used in the headlamp. Your engineers contemplate a clear-lensed headlamp, and would like to engrave these markings on a visible area of the inner bezel where they are easily seen from the outside. You ask for confirmation that this would meet the "spirit" of the requirement even if the definition of lens doesn't apply to an interior part.
The Federal motor vehicle safety standards specify objective requirements. Failure to mark the lens in the manner specified by Standard No. 108 would create a noncompliance with the standard. Paragraphs S7.2(a) and S7.5(g) are very specific in their requirements that the lens be marked, and do not allow alternative marking of the bezel if the lens is clear.
If you have any questions, you may refer them to Taylor Vinson of this Office (FAX 202-366-3820).
Samuel J. Dubbin Chief Counsel ref:108 d:4/25/96