Interpretation ID: 15826.ztv

Herr Olaf Schmidt
Hella KG Hueck & Co.
Rixbecker Strabe 75 75
59552 Lippstadt
Germany

Dear Herr Schmidt:

This is in reply to your letter of August 15, 1997, to Richard Van Iderstine of this agency, concerning the conformity of a new headlamp design to the requirements of Federal Motor Vehicle Safety Standard No. 108.

You report that Hella has designed a headlamp to be visually aimable in accordance with the amendments to Standard No. 108 that were published on March 10, 1997. To facilitate the production of new vehicles on which the headlamp will be installed, the headlamp will incorporate a bubble-vial type of vehicle headlamp aiming device (VHAD) which is not required for visually aimable headlamps. The headlamp will be provided "with an initial pre-setting so that the location of the cut-off line [of the beam] corresponds very close (less than one tenth of a degree) to the indication of the bubble scale." You assure us that "The VHAD will not interfere [with] the aiming and performance of the headlamps" and that "[t]his auxiliary vertical VHAD is intended as a production aid and will not be mentioned in the owner's manual of the relevant car."

Paragraph S7.8.5. of Standard No. 108 in pertinent part requires headlighting systems installed on motor vehicles to "be aimable with at least one of the following" methods, which are specified as an externally applied aiming device, an on-vehicle headlamp aiming device, or by visual/optical means, each method to be "as specified" by a cited paragraph of Standard No. 108. This means that a headlamp may be both visually/optically aimable and aimable using a VHAD. However, the VHAD must conform to the requirements of Standard No. 108, one of which is that it be capable of horizontal aim adjustment. The Hella "auxiliary VHAD" does not include this feature. Therefore, the headlamp design you contemplate would appear not to conform to Standard No. 108.

If you have any further questions, please do not hesitate to ask us.

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d.2/18/98