Interpretation ID: 16120.ztv

Mr. Scott Patten
Government Relations Coordinator
Kawasaki Motors Corp., U.S.A.
P.O. Box 25252
Santa Ana, CA 92799-5252

Dear Mr. Patten:

This is in reply to your letter of September 19, 1997, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 108 as it pertains to motorcycle headlamps.

You have asked whether the shape of the outer lens of a motorcycle headlamp must be symmetrical in a headlamp design in which "the effective area of the reflector is symmetrical." The bulb, reflector, and lens are centered on the vertical centerline of the motorcycle. You believe that an asymmetrical outer headlamp lens is permissible as it is not specifically prohibited. You have also cited in support a letter from the NHTSA Chief Counsel dated January 12, 1987, to Stanley Electric. Co. stating that "the effective area of the reflector is used as the reference for headlamp location, rather than the outer edge of the headlamp lens."

We confirm your belief that an asymmetrtrical outer lens for a motorcycle headlamp is permissible under Standard No. 108. Table IV requires a motorcycle with a single headlamp to have the lamp located on the vertical centerline of the vehicle. As long as the bulb, reflector, and lens are centered on the vertical centerline, as you have indicated, the headlamp outer lens need not be the conventional circular or rectangular shape.

If you have any questions, you may refer them to Taylor Vinson of this Office (202-366-5263).

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d.10/20/97