NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
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NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: nht78-2.15OpenDATE: 03/15/78 FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA TO: Vetter Fairing Company TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of February 1, 1978, on motorcycle headlighting. You have asked whether the prohibition in SAE J580a Sealed Beam Headlamp against headlamp covers applies to a motorcycle. You have also asked the reason for the prohibition. SAE J580a Sealed Beam Headlamp is incorporated by reference in Table III of Standard No. 108 as one of the standards applicable to headlamps for use on passenger cars, and on multipurpose passenger vehicles, trucks, and buses whose overall width is less than 80 inches. One of the SAE standards incorporated by reference for motorcycle headlighting is J584 which, as an option, allows motorcycles to be equipped with headlamps "meeting the requirements of SAE J579" (i.e. passenger car sealed beam headlamps). There is no reference in J579a to J580a, and we therefore do not read the prohibition against headlamp covers as applying to motorcycles equipped with sealed or unsealed headlamps. The reason for the prohibition is the degradation in Light output that can result from condensation under unsealed glass covers or from obscuration by grilles in front of the lens. SINCERELY, Vetter Fairing Company February 1, 1978 Office of Chief Council Joseph J. Levin, Jr. National Highway Traffic Safety Admin. Dear Sir: After reviewing Title 49 Code of Federal Regulations 571.108, Motor Vehicle Safety Standard Number 108, Lamps, Reflective Devices and Associated Equipment, I find a need to have several points of this regulation, relevant to our business, clarified and interpreted per your office. Table III, Required Motor Vehicle Lighting Equipment, Item - Headlamps, references the applicable SAE standard or recommende practice for passenger cars, multipurpose passenger vehicles, trucks and buses to be, in part, SAE J580a, June 1966. Contained within SAE J580a, sealed beam headlamp, under General Requirements it states "A headlamp, when in use, shall not have any styling or other feature, such as a glass cover or grille in front of the lens." Is it correct to assume that this prohibition does not apply to a motorcycle or to a motorcycle with attached side car? Also would you please state the reason/s why passenger cars are prohibited from having any styling or other feature, such as a glass cover or grille in front of the lens when a headlamp is in use? Table III, Required Motor Vehicle Lighting Equipment, Item - Headlamps, references the applicable SAE standard or recommended practice for motorcycles to be, in part, SAE J584, April 1964. Standard SAE J584, motorcycle and motor driven cycle headlamps makes no mention of any prohibition of having any styling or other feature, such as a glass cover or grille in front of the lens when a headlamp is in use. Is it correct to infer that it is legal and within the scope of Motor Vehicle Safety Standard Number 108, to have styling or other feature, such as a glass cover, or plastic cover or grille in front of the lens when a headlamp is in use on a motorcycle or on a motorcycle with attached side car? It is in the intent of Vetter Fairing Company as a manufacturer of motorcycle accessories to conceive, research, design, produce, manufacture and market motorcycle accessories which meet or exceed all Federal Motor Vehicle Safety Standards of the National Highway Traffic Safety Administration, Department of Transportation. Your review of any and all applicable regulations relevant to our business is appreciated and your interpretation of such regulations pertaining to the above questions is requested so that we can meet our obligations, to consumers, to manufacturer motorcycle accessories which are safe and which comply with all Federal Motor Vehicle Safety Standards. W. W. Schwartz Technical Engineer Research & Development Dept. cc: C. VETTER C. PERETHIAN
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ID: nht91-6.15OpenDATE: October 7, 1991 FROM: Paul Jackson Rice -- Chief Counsel, NHTSA TO: Jon Nisper -- K.B. Lighting, Inc. TITLE: None ATTACHMT: Attached to letter dated 8-23-91 from Jon Nisper to Jerry Medelin (OCC 6403) TEXT: This responds to your FAX of August 23, 1991, to Jere Medlin of this agency. You have enclosed a drawing of a combination headlamp/turn signal lamp assembly that depicts two possible positions ("Case l," "Case 2") for the inboard wall. With respect to each, you have asked "where should the 100mm separation be measured for turn signal headlamp position?" Let me begin by noting that there is no requirement in Standard No. 108 that front turn signal lamps be separated from headlamps by at least 100mm. However, if there is less than a 100mm separation of those lamps, S5.3.1.7 of Standard No. 108 provides that the multiplier applied to obtain the required minimum luminous intensities for the lamps shall be 2.5. NHTSA determines the distance of the separation pursuant to the provisions of paragraph 5.1.5.4.2 of SAE Standard J588 NOV84, "Turn Signal Lamps for Use on Motor Vehicles Less Than 2032 mm in Overall Width." That paragraph provides the following means of measuring spacing: "Spacing for a front turn signal lamp which primarily employs a reflector (for example, one of parabolic section) in conjunction with a lens to meet photometric requirements, shall be measured from the geomeric centroid of the front turn signal functional lighted area to the lighted edge of the low beam headlamp or any additional lamp used to supplement or used in lieu of the lower beam, such as an auxiliary low beam or fog lamp." We would apply this as follows. You stated in your letter that the inboard walls in your proposed headlamp/turn signal assembly serve no functional purpose. We interpret this as meaning that neither the inboard wall in Case 1 or Case 2 shown in your drawing would be used optically in the headlamp. Under this assumption, and the assumption that no direct light from the bulb filament illuminates the outer edges of the headlamp lens nearest the turn signal, the lighted edge of the headlamp reflector would end where the relevant inboard wall meets the reflector. Pursuant to SAE Standard J588 NOV 84, one would then take a vertical plane that is parallel to the axis of the headlamp bulb, and project it from the end of the lighted edge of the reflector (i.e., where the respective inboard wall meets the reflector) onto the lens. You have already drawn this as a line in the drawing enclosed with your FAX. Next, take the axis of the turn signal bulb and project it onto the lens (this line also exists in your enclosed drawing). To determine the separation, one would then measure the distance between the projected points on each lens. Should the headlamp lens area between the turn signal and the projected vertical wall line onto the headlamp lens be lighted, either on purpose or inadvertently, then the actual lighted edge of the headlamp would be used for measurement purposes. |
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ID: 06-005429as-6OpenMr. Kiminori Hyodo Deputy General Manager, Regulation & Certification Koito Manufacturing Co., Ltd. 4-8-3, Takanawa Minato-Ku Tokyo Japan Dear Mr. Hyodo: This responds to your letter, in which you seek clarification as to the definition of the optical axis for a lower beam headlamp using light-emitting diodes (LEDs) under Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices, and Associated Equipment. Specifically, you asked how one would determine the optical axis for a LED lower beam headlamp, where respective LEDs provide different light intensities or beam configurations. As discussed below, it is our opinion that the optical axis for a visual/optical aim headlamp is the reference axis necessary to assure proper horizontal and vertical alignment of the optical aiming equipment. It is up to the manufacturer to decide how to determine that axis and to select the location of the required marking. This interpretation would apply to any visually/optically aimed headlamp regardless of light source type. By way of background, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue FMVSSs that set performance requirements for new motor vehicles and items of motor vehicle equipment (see 49 U.S.C. Chapter 301). NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Instead, manufacturers are required to self-certify that their products conform to all applicable safety standards that are in effect on the date of manufacture. FMVSS No. 108 specifies requirements for original and replacement lamps, reflective devices, and associated equipment. NHTSA selects a sampling of new vehicles and equipment each year to determine their compliance with applicable FMVSSs. If our testing or examination reveals an apparent noncompliance, we may require the manufacturer to remedy the noncompliance, and may initiate an enforcement proceeding if necessary to ensure that the manufacturer takes appropriate action. Your letter asked what constitutes the location of the optical axis in a situation in which LEDs of varying intensity are used in a headlamp. You described a situation in which one LED from an array of LEDs serves to provide the dominant intensities toward the center of the beam pattern and determines a major characteristic of a cut-off. You asked if it would be appropriate to use that element to determine the optical axis. You also ask this question assuming a condition where respective LEDs are directed differently to constitute respective parts of the low-beam illumination. These questions caused the agency to closely examine the meaning of optical axis in order to assure proper headlamp aiming. In your letter, you cited a prior agency interpretation (December 21, 2005 letter to Mr. Takayuki Amma) regarding lower beam headlamps using several LEDs of equal light intensities, and our conclusion that the optical axis shall always correlate to the actual photometric output of the lamp. In view of your latest inquiry, we reexamined our 2005 interpretation relative to the determination of the optical axis. In our 2005 interpretation, we expressed agreement that the optical center would serve as an optical axis of a lower beam headlamp. We also agreed with your recommended approach and said that for LED lower beam headlamps, the optical center should be determined as the geometric center of the portion of the lens that is illuminated by the LED light sources. While we continue to believe this could be a valid approach, manufacturers may choose other methods as well. For example, with LED light sources of varying intensity, a manufacturer could conclude that the geometric center of the illuminated lens might not be accurate for marking the lamp for aiming purposes. The agency notes that the term optical axis as used in FMVSS No. 108 may be inconsistent with the encyclopedic definition of the phrase. For visually/optically aimed headlamps, the term optical axis, as it is used in Standard No. 108, refers to the reference axis (a.k.a. mechanical axis) of the headlamp. Given this, we have reexamined a second point from the 2005 letter, in which we stated that the center of the emitted light is always taken to be the center of the optical axis. In saying this, we were quoting a January 14, 1976 letter of interpretation to the Department of California Highway Patrol. Upon closer examination, the 1974 letter addressed the optical axis (i.e., the mechanical or reference axis) in turn signals, not headlamps. As turn signals are symmetrical, the center of light emitted should always constitute the reference axis. However, as headlamps are asymmetrical, the quoted portion of the 1974 letter does not apply to headlamps. Paragraph S7.8.5.3(f) of FMVSS No. 108 requires that a visually/optically aimed headlamp include a mark or markings identifying the optical axis of the headlamp. The location of this mark or markings is to be determined by the headlamp manufacturer. Once chosen, the mark establishes the reference axis that will be used to assure proper horizontal and vertical alignment of the aiming screen or optical aiming equipment with the headlamp being aimed. NHTSA will use this mark to identify the reference axis, and will conduct its compliance testing accordingly. Finally, we note that this interpretation broadens flexibility for manufacturers under the rule and, as such, does not amount to a change implicating compliance issues for manufacturers currently relying on the opinions in our previous letters. If you have any further questions, please contact Ari Scott of my staff at (202) 366-2992. Sincerely, Anthony M. Cooke Chief Counsel ref:108 d.5/25/07 |
2007 |
ID: aiam3788OpenMichael J. Schmitt, Counsel, Yamaha Motor Corporation, USA, 6555 Katella Avenue, Cypress, CA 90630; Michael J. Schmitt Counsel Yamaha Motor Corporation USA 6555 Katella Avenue Cypress CA 90630; Dear Mr. Schmitt: This is in response to your letter asking for an interpretation on th permissibility of using two type 2A1 headlamps mounted symmetrically disposed about the vertical centerline of the motorcycle.; Federal Motor Vehicle Safety Standard (FMVSS) No. 108, 'Lamps Reflective Devices, and Associated Equipment (sic) states in S4.1.1.34 that a motorcycle may be equipped with one of the following headlamp systems, one of which is the 'A' type headlamp system described as follows:; >>>Type 1A1 or Type 1A . . . . 1 lamp and either Type 2A1 or Type 2A . . . . 1 lamp<<<< The standard is specified this way because the 2A1 lamp is a lower bea lamp and the 1A1 is an upper beam lamp. While the 2A1 lamp does have an 'upper beam', photometrically it provides only 'fill-in' light. The 1A1 lamp provides the high output upper beam. It is not possible to achieve safe upper beam light using only the 2A1 lamp, regardless of how many are used. Therefore, your proposed headlighting application would not be permitted by FMVSS No. 108.; Sincerely, Barry Felrice, Acting Associate Administrator for Rulemaking |
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ID: 18369.ztvOpenMasao Muraoka, Deputy General Manager Re: Interpretation of Replaceable Bulb Headlamp Dear Mr. Muraoka: This is in reply to your letter of July 3, 1998, to the Associate Administrator for Safety Performance Standards, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108. In the future, please address requests for interpretation to the Chief Counsel. You have called our attention to Standard No. 108's definition of "replaceable bulb headlamp," which means
According to your letter, Koito is considering manufacturing a replaceable bulb headlamp "whose lens is bonded not with one adhesive agent, but with using some screws or clamps." The lens is separable from the lamp body for purposes of recycling, and Koito has no intention of providing a replacement lens. The chemical resistance test (S8.10.1) and the corrosion test (S8.10.2) apply to replaceable bulb headlamps with replaceable lens. You ask for an interpretation that the headlamp design Koito contemplates is not required to meet these two tests. Although Standard No. 108 does not define a "bonded lens and reflector assembly," we use that term to denote a connection which is indivisible and permanent, such as provided by adhesives, rather than a connection that is divisible and impermanent such as provided by screws and clamps. I enclose a copy of an interpretation from the Chief Counsel, dated January 13, 1987, to Dr. Ernst of Hella KG Hueck & Co. explaining the agency's views. Because the lens/reflector assembly is not bonded, and the lens is separable from the reflector, we regard this as a headlamp with a replaceable lens. Unless the headlamp complies with S7.8.5.2 or S7.8.5.3, it would be neither a "replaceable bulb headlamp" nor an "integral beam headlamp" as defined by Standard No. 108. This means that the headlamp could not be used in applications where certification of conformance to Standard No. 108 is required. Sincerely, |
1998 |
ID: 16120.ztvOpenMr. Scott Patten 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, |
1997 |
ID: 7113Open Mr. Shigeyoshi Aihara Dear Mr. Aihara: This responds to your letter of March 16, 1992, requesting an interpretation of the applicability of the moisture prohibition of S7.4(i)(6) of Federal Motor Vehicle Safety Standard No. 108. Initially, we would like to call your attention to the fact that S7.4(i)(6), which you quoted in its entirety, was amended on March 11, 1991, to delete the requirement that a headlamp meet the photometric requirements after a humidity test. S7.4(i)(6) now states in pertinent part that, after a humidity test conducted in accordance with S8.7, "the inside of the headlamp shall show no evidence of delamination or moisture, fogging or condensation visible without magnification." You have attached a drawing of a vented headlamp with an onboard aiming system. The headlamp is available with two different types of bubble indicators. Your first question is: "After the humidity test, both types . . . show the fogging in the location as shown in attached sketches. But, this fogging is gone at normal temperature. * * * Is such fogging acceptable after the humidity test?" Your second question is whether "'the inside of the housing' means the lens and reflector portions" or "the entire inside portion of headlamps?" The humidity test was adopted for replaceable bulb headlamps in l983. Allowing humidity or water in headlamps causes slow degradation of the reflector over the long term. The presence of humidity results in spots on the reflector and lens, and eventual photometric failure. The humidity test is designed to assure that the vents in vented headlamps eliminate moisture in the headlamp when exposed to air flow with the headlamps off, thus assuring adequate performance in long term use. The provision for onboard headlamp aiming devices was not adopted until 1989, and, with respect to replaceable bulb headlamps, did not specify that they be located within the headlamp. From the foregoing, it is evident that the humidity test for replaceable bulb headlamps was not adopted to address a problem inherent in the exposure of onboard aiming devices to moisture. These devices were not in use at the time the humidity test was added to Standard No. 108, and they do not contribute directly to the photometric performance of the headlamp. From the diagram you enclosed, the aiming device appears located behind the reflector. It is not possible to determine from your letter whether moisture forms on the exterior or the interior of the aiming device. Although S7.4(i)(6) prohibits moisture "inside the headlamp" and the aiming device is located inside the headlamp, we would not read the prohibition as extending to the aiming device if the moisture occurs inside that device. Even if the moisture occurs on the exterior of the aiming device, it does not affect the photometric properties of the headlamp. The agency does not wish to impose inadvertent design restrictions that are not directed towards safety, and therefore regards any moisture that may occur on the exterior of the aiming device as outside the prohibition of S7.4(i)(6). This interpretation, however, is limited to the specific design that you have presented. Sincerely,
Paul Jackson Rice Chief Counsel ref:108 d:5/6/92 |
1992 |
ID: 22204.ztvOpenM. Guy Dorleans Dear M. Dorleans: This is in reply to your letter of September 20, 2000, asking for interpretations of 49 CFR Part 564 and Federal Motor Vehicle Safety Standard No. 108. Your company is presently developing "a headlamp which incorporates a replaceable gas-discharge light source with a ballast as a dedicated power supply." The light source is one for which information has been filed pursuant to 49 CFR Part 564 in Docket No. National Highway Traffic Safety Administration (NHTSA) 98-3397. The ballast, which is "completely encased in the headlamp, is not removable from the headlamp, and is not sold as a spare part," is not part of the list. You believe that the requirements of Part 564 do not apply to this headlamp and that you are not required to submit the information specified in Sec. 564.5(d)(1), (2), and (3). Under the provisions of Sec. 564.5(d), a manufacturer may request modification of a light source for which information has previously been submitted. Because the ballast is a listed part necessary for interchangeability (Sec. 564, Appendix B, paragraph V, subsection A), you must submit the ballast part number. Even though the ballast is incorporated in the headlamp, and its part number is the same as the headlamp, its part number must be submitted because it is a modification of the basic information regarding light sources whose information is already listed in the Part 564 docket. You have a question relating to Standard No. 108 as well. Paragraph S7.7(e)(1) through (e)(7) specifies marking requirements for ballasts necessary for operation of replaceable light sources. One face of the ballast in Valeo's headlamp is visible from outside the headlamp. You have asked whether the ballast in the Valeo headlamp must be marked in accordance with S7.7(e). Paragraph S7.7(e) is the only NHTSA regulation that imposes specific requirements on ballasts. The paragraph does not distinguish between ballasts that are integrated into a headlamp and those that are exterior to it. The intent of the marking requirement is to inform the reader primarily of product identification, rated laboratory life of the light source/ballast combination, warning of potential shock hazard, and a DOT certification to these requirements. In our opinion, these markings are required under the headlamp design you posit, one in which a ballast is incorporated into the headlamp housing and is not replaceable alone. If you have further questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely, Frank Seales, Jr. ref:108 |
2000 |
ID: mills.ztvOpenMr. Robert G. Mills Dear Mr. Mills: This is in reply to your fax of August 22, 2003, with reference to paragraph S7.9.6.2 of Federal Motor Vehicle Safety Standard No. 108. You described a single motorcycle headlamp "with two separate illuminating compartments, one of which contains the lower beam and the other the upper beam." The projectors providing each beam would be mounted at the same height and symmetrically disposed around the vertical centerline of the motorcycle. When only the lower beam is activated, the lighting array would be asymmetric; however, the lower beam remains activated when the upper beam is activated, resulting in a symmetric lighting display. You are aware of our 1994 and 1995 interpretations to Jeffrey Shetler of Kawasaki which, in your view, "clearly indicate that an asymmetric lower beam coming from a single headlamp is not considered to comply with the standard." You have asked us to reconsider these interpretations in view of the fact that paragraph S7.9.6.2(c) permits asymmetrical lighting in a two-headlamp motorcycle headlighting system when an upper beam headlamp and a lower beam headlamp are mounted on either side of the vertical centerline. Our previous letters to Mr. Shetler were based upon Table IV of Standard No. 108 as in effect in 1994 and 1995. Table IV stated that a motorcycle headlamp must be located "On the front, on the vertical centerline, except that if two are used they shall be symmetrically disposed about the vertical centerline." The headlamp described by Mr. Shetler would be mounted on the vertical centerline, but, as we informed him, "the beams provided by the headlamp are located on either side of the centerline and are therefore asymmetrical in relation to the centerline of the motorcycle when either beam is activated." We did not consider this a configuration that met Table IV. However, since the time of those earlier interpretation letters, relevant changes have been made to FMVSS No. 108. Today, as a result of a 1998 final rule (63 FR 42582, August 10, 1998) that specifically allows asymmetrical headlamp beams on motorcycles, a single-headlamp beam configuration as you have described would comply with the requirements of S7.9.6.2(a). Furthermore, in this case, we note that all compartments that are wired to illuminate in the upper beam mode must be illuminated when determining compliance with the upper beam photometry requirements. If you have further questions, you may refer them to Mr. Eric Stas of this office (202-366-5263). Sincerely, Jacqueline Glassman ref:108 |
2003 |
ID: aiam4698OpenHerr T. Spingler Abt. K2/ELE2 Robert Bosch GmbH; Herr T. Spingler Abt. K2/ELE2 Robert Bosch GmbH; Dear Herr Spingler: This is in reply to your FAX of July l9, l990, t Richard Van Iderstine of this agency asking for confirmation of an oral interpretation provided you by Jere Medlin, Office of Rulemaking, with respect to replaceable bulb headlamps. Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, defines (section S3) a replaceable bulb headlamp as 'a headlamp comprising a bonded lens and reflector assembly and one or two standardized replaceable light sources.' In Europe you fix the lens to the reflector assembly with a rubber seal and clips. For the U.S. market you propose to add 'silicone-glue at four places between lens and housing to prevent removal of the lens.' Mr. Medlin informed you that this would be a 'bonded lens and reflector assembly.' The standard does not define 'bonded', but the intent of the definition is that, once the lens is joined to the reflector assembly, it shall not be separable. Any method of adhesion that accomplishes this would be a sufficient bond for purposes of the definition. If the application of silicone glue at four places between the lens and the reflector assembly is sufficient to prevent manual separation of the lens from the assembly, then it would be a sufficient bond. I hope that this answers your question. Sincerely,, Paul Jackson Rice Chief Counsel; |
Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.