Interpretation ID: nht75-2.39

DATE: 05/30/75

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Stanley Electric Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of May 15, 1975, regarding Federal Motor Vehicle Safety Standard (FMVSS) No. 108 requirements for Type 1A and 2A automotive headlamps.

The following answers are provided for your specific questions

1. FMVSS No. 108 would not prohibit use of metal-back Types 1A and 2A headlamps that conform to all requirements of the standard.

2. The National Highway Traffic Safety Administration does not issue approvals on automotive equipment. The equipment manufacturer self certifies that the equipment conforms to the applicable FMVSS. The various states may, however, require equipment approval. Information on these approvals may be obtained from the American Association of Motor Vehicle Administrators, 1201 Connecticut Avenue, Washington, D. C. 20036.

3. The drawings of the Type 1A and 2A headlamp submitted with your letter, indicate that aiming pads have been deleted. Aiming pads are required by FMVSS No. 108.

For your information enclosed is a copy of FMVSS No. 108, which includes requirements for Types 1A and 2A headlamps, and a copy of Docket No. 75-8 Notice 1, that proposes to allow use of the four-lamp rectangular systems indefinitely.