Magnet Marelli UK Ltd.
Walkmill Lane, Cannock
Dear Mr. Law:
This is in reply to your FAX of April 30, 1997, to Mr. Van Iderstine of this agency asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it applies to "optical centre marking on visually aimable headlamps."
You present three drawings ("a," "b," and "c") of rectangular headlamps with various markings and ask are "any of these options mandatory/preferred/unacceptable."
Paragraph S188.8.131.52(f)(1) of Standard No. 108 requires that there "be a mark or markings identifying the optical axis of the headlamp," and that "[t]he manufacturer is free to choose the design of the mark or markings." Option "a" shows a marking in the center of the rectangle, whereas options (b) and (c) have four markings, one each at the center of each of the four sides.
With respect to your rectangular headlamp drawings, the optical axis runs directly through the center of the headlamp at 90 degrees to the lens face. This means that only option "a" identifies the optical axis of the rectangular headlamps. Options (b) and (c) are insufficient to identify the optical axis on the rectangular headlamp drawings and thus do not meet the requirements of paragraph S184.108.40.206(f)(1).
If you have further questions, you may refer them to Taylor Vinson of this office (FAX 202-366-3820).
Acting Chief Counsel