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Interpretation ID: nht95-5.5

TYPE: INTERPRETATION-NHTSA

DATE: December 18, 1995

FROM: Tilman Spingler -- Robert Bosch GmbH

TO: Samuel Dubbin -- Chief Counsel

TITLE: Request for interpretation

ATTACHMT: 1/29/96 letter from Samuel J. Dubbin to Tilman Spingler (A44; Std. 108)

TEXT: with todays optical and mechanical methods it will be possible to achieve both high- and lowbeam of a headlamp with only one single lightsource. Are there any reservations against on the basis of the requirements in FMVSS 108? If no, which photometric requirements are applicable? Such a headlamp will in any case meet the photometric requirements for lower beam in the lower beam mode and for upper beam in the upper beam mode. The position on the vehicle is the same as for a 2-headlamp-system (e.g. wi th HB1-, HB2-, HB5-bulbs).