Mr. Tadashi Suzuki
Manager
Automotive Equipment
Legal & Homologation Section
Stanley Electric Co. Ltd.
2-9-13, Nakameguro, Meguro-ku
Tokyo 153, Japan

Dear Mr. Suzuki:

This responds to your letter of March 14,1997, asking for an interpretation of paragraphs 7.5(d)(1) and (e)(1) of Federal Motor Vehicle Safety Standard No. 108.

Pargraph S7.5(d)(1) applies to headlamps equipped with dual filament replaceable light sources and requires that

"Headlamps designed to conform to the external aiming requirements of S7.8.5.1 shall have no mechanism that allows adjustment of an individual light source, or, if there are two light sources, independent adjustments of each reflector."

Paragraph S7.5(e)(1) applies to a headlamp system equipped with any combination of replaceable light sources except those specified in S7.5(d), and requires that

"Headlamps designed to conform to the external aim requirements of S7.8.5.1 shall have no mechanism that allows adjustment of an individual light source, or, if there are two replaceable light sources, independent adjustments of each reflector."

You have enclosed a sketch of two headlamp designs, called "Example 1" and "Example 2." You believe that "Example 1" can meet both requirements and that "Example 2" cannot due to the independent adjustment of the two reflectors. You ask whether or not your interpretation is correct.

"Example 1" depicts a headlamp with two light sources (Type HB3 and Type HB4), and "Reflector" (Upper Beam & Lower Beam)" joined at the center, and a vehicle headlamp aiming device (VHAD) identified as "VHAD (Upper Beam & Lower Beam)". As noted above, S7.5(d)(1) applies to headlamps with dual filament replaceable light sources. Type HB3 and Type HB4 are single filament replaceable light sources. Therefore, S7.5(d)(1) does not apply to your "Example 1" headlamp design. Additionally, because "Example 1" has a VHAD, paragraph S7.5(d)(1) does not apply, being intended for externally-aimed headlamps. For the same reason, it does not need to comply with S7.5(e)(1).

"Example 2" depicts a headlamp with two light sources (Type HB3 and Type HB4), and with two separate reflectors. One light source is identified as "Upper Beam" and the other as "Lower Beam." Each light source has its own VHAD. As with "Example 1", paragraph S7.5(d)(1) does not apply to this headlamp design because it incorporates single filament light sources. Also, as with "Example 1", paragraph S7.5(e)(1) does not apply.

In summary, neither S7.5(d)(1) nor S7.5(e)(1) apply to the examples. Because both Examples appear to be equipped with "on-vehicle aiming" (see paragraph S7.8.5.2), either Example would appear to comply with the relevant provisions of S7.5(e).

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

Sincerely,

John Womack

Acting Chief Counsel

ref:108

d:4/25/97