Interpretation ID: nht73-1.30
DATE: 10/25/73
FROM: E. T. Driver; NHTSA
TO: Marchal America
TITLE: FMVSS INTERPRETATION
TEXT: This responds to your letter #8495, dated October 5, 1973 to the National Highway Traffic Safety Administration concerning the legality of an automotive headlamp having a sealed metal reflector, glass lens arrangement. It is understood from your letter that such a headlamp would meet all requirements of Federal Motor Vehicle Safety Standard No. 108, including photometric and electrical performance, interchangeability and mechanical aiming.
Specifically your question is: "Would a hermetically sealed metal and glass headlamp, (one in every way interchangeable with existing approved sealed beams except that the reflector would be metal instead of glass), be acceptable under current federal regulations?"
The answer to your question is "yes".