Interpretation ID: 21078.ztv

M. Guy Dorleans
International and Regulatory Affairs Mgr.
Valeo
34 rue Saint-Andre
93012 Bobigny
France

Dear M. Dorleans:

This is in reply to your letter of December 17, 1999, asking for confirmation that a new headlamp design is in conformance with Federal Motor Vehicle Safety Standard No. 108.

The headlamp incorporates three replaceable light sources. The upper beam is provided by two bulbs called "HB nb1" and "HB nb2." The lower beam is also provided by two bulbs, the first being "LB nb1" (the same bulb as "HB nb1") and by bulb "LB nb2." The headlamp meets the photometric requirements of Table 17-2 in each beam mode.

Paragraph S4 Definitions of Standard No. 108 defines a "replaceable bulb headlamp" in pertinent part as "a headlamp comprising . . . one or two replaceable light sources . . . ." Because the Valeo design incorporates three replaceable light sources, it does not comply with the definition, and thus is not a replaceable bulb headlamp design allowed by Standard No. 108.

We are, however, considering amending the definition of "replaceable bulb headlamp" to allow more than two light sources. On November 12, 1998, we proposed a revision of Standard No. 108 (63 FR 63258). With respect to proposed S7.4.5 Arrangement and marking of upper and lower beams, and S7.5.3 Arrangement and marking of upper and lower beams, we remarked (at 63260) that these paragraphs anticipate "future headlamp designs with an array of light sources . . . ." But we overlooked proposing a corresponding amendment to "replaceable bulb headlamp" which would define it as comprising one or more light sources. Because the proposal presented the issue of multiple-bulb replaceable bulb headlamps, we will consider for purposes of a final rule including a redefinition of "replaceable bulb headlamp" that would accommodate headlamps such as Valeo's. We plan to announce a decision during 2000.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.3/10/2000