Interpretation ID: aiam3010
Chief
Overseas Technical Section
Technical Administration Department
Koito Manufacturing Co.
Ltd.
Shizuoka Works
500
Kitawaki
Shimizu-Shi
Shizuoka-Ken
JAPAN;
Dear Mr. Iwase: This is in reply to your letter of January 29, 1979, to Bill Eason wit respect to headlamp lens marking. Mr. Eason is no longer associated with the Office of Rulemaking and we regret the delay in writing you.; You have asked for a confirmation of your interpretation that: >>>'The headlamp designed to conform to J579c shall be provided wit the lens marking specified in S4.1.1.21 of FMVSS No. 108 *even if the upper beam headlamp maximum output is lower than the conventional maximum restriction of 37,500 cd*.'<<<; You are correct that S4.1.1.21 permits the new code marking fo headlamps designed to conform to SAE Standard J579c even if the upper beam headlamp maximum output is lower than the maximum of 75,000 cds permissible under J579c or the previous maximum of 37,500 cd of J579a. But because the code could be misleading, we are considering proposing an amendment of Standard No. 108 that would delete the new code requirement for all headlamps whose maximum candela does not exceed a certain value, such as 40,000 cd.; Sincerely, Frank Berndt, Acting Chief Counsel