Interpretation ID: aiam3761
Westfalische Metall Industrie KG
Hueck & Co.
Postfach 28 40
4780 Lippstadt
Germany;
Dear Mr. Wuddel: This is in reply to your letter of September 9, 1983, to August Burget of this agency. With reference to the recent amendment to Motor Vehicle Safety Standard No. 108 permitting semi-sealed replaceable bulb headlamp systems, you have asked whether a headlamp assembly would be allowed which also incorporated a European H1 or H2 bulb, 'for an auxiliary driving beam or a front fog lamp, as our customer requests it.'; It is our understanding that the H1 bulbs are commonly used in Europea lamps as the principal lighting source, and that H2 bulbs are used in high intensity supplemental front lamps. Therefore, use of one of these bulbs in a replaceable bulb headlamp would create, in effect, a system of four headlamps. The agency recently denied a petition by Volkswagen for a four- lamp system at this time using the standardized replaceable light source (copy enclosed), because of unresolved issues. We therefore are currently unable to allow a system such as you propose with the H1 or H2 bulb in a common housing with the standardized replaceable light source, creating in effect a four- lamp headlamp system. Further, paragraph S4.1.3 of Standard No. 108, prohibits the installation of additional lighting equipment which impairs the effectiveness of lighting equipment required by Standard No. 108, and there is the distinct possibility that this could occur through incorporation of the H1 and H2 bulbs.; Use of the H1 and H2 bulbs in separate and independent units fo driving or fog lamps remains permissible, subject to regulation by the individual American States, as these items are not covered by Standard No. 108.; You may be interested to know that Volkswagen of America has recentl petitioned us for rulemaking that would allow use of the H4 bulb instead of the standardized replaceable light source in replaceable bulb headlamp systems. A decision is pending whether to grant this petition.; Sincerely, Frank Berndt, Chief Counsel