Interpretation ID: 20837.ztv

Mr. Tadzio Suzuki
Manager
Automotive Equipment
Regulation & Homologation Sect.
Stanley Electric Co., Ltd.
2-9-13, Nakameguro, Meguro-ku
Tokyo 153-8636
Japan

Re: Headlamp Optical Axis Marking

Dear Mr. Suzuki:

This is in reply to your letter of October 15, 1999, asking whether the marking intended to designate the optical axis on a new headlamp complies with S7.8.1(b) of Federal Motor Vehicle Safety Standard No. 108. This section requires the optical axis of visually/optically aimable headlamps to be designated by a mark.

The headlamp assembly will be used on cars intended both for Japan/Europe and the United States and has a common lens, though the light sources will differ. The headlamp intended for Japan/Europe will contain two light sources, each with its own reflector, whereas the U.S. version will be equipped with a single HB5 bulb and a single reflector. The optical axes will be marked on the lens, the U.S. version with a single circle, and the other version with two small diamonds. You relate that the lens is a clear one so that the light sources can be seen easily from outside the lens, and do not believe that multiple markings will create confusion.

The lens is properly marked as required by S7.8.1(b). The two non-required optical axis markings are permissible so long as they do not cause confusion with respect to the required marking. You indicate that the HB5 light source can be clearly seen behind the transparent lens. Therefore, we agree with you that there should be no confusion about the location of the optical axis of the U.S. version headlamp when it is necessary to assure proper horizontal and vertical alignment of the aiming screen or optical aiming equipment.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.3/27/00