Mr. Kiyoshi Narabu
General Manager
Technical Department
Ichikoh Industries, Ltd.
80 Itado, Isehara-City
Kanagawa, 259-11 Japan

Dear Mr. Narabu:

This responds to your letter of March 7, 1997, with reference to paragraph S7.7(e) of Standard No. 108 requiring permanent markings of ballasts used in high intensity discharge headlamps.

You have enclosed samples of labels to be stuck to ballasts and a sample of a plate to which the label is affixed, and ask whether these are "permanent" markings within the meaning of the standard.

We were able to peel back and remove in an undamaged condition the label on the sample plate that you enclosed. Therefore, it does not meet the requirement of paragraph S7.7(e) that the markings be permanent. We regard marking by labels as "permanent" if the labels cannot be removed without their destruction.

We note that the marking itself is in the Japanese language. We are unable to tell whether the marking conforms with the warning and other information required on ballast markings by the remainder of paragraph S7.7(e). Thus, the label must also be in the English language to comply fully with the requirements of this paragraph.

If you have further questions about this letter, you may FAX them to Taylor Vinson of this Office (202-366-3820).

John Womack
Acting Chief Counsel