Interpretation ID: 22690.ztv

Mr. James Haydn
Koito Europe Ltd.
Kingswood Road
Hampton Lovett Industrial Estate
Droitwich Spa
Worcestershire WR9 0QH
England

Dear Mr. Haydn:

This is in reply to your e-mail of February 13, 2001, to Richard Van Iderstine of this agency. You have asked whether a new headlamp design complies with the specifications of Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment.

The headlamp has a "Bi-xenon unit that produces the low and high beams together with a separate high beam in the same assembly." You understand that you "can only have the Bi-xenon unit for the photometric performance, therefore my questions are, for the separate high beam." You have asked whether you are correct in assuming that the separate upper beam cannot be used under Standard No. 108.

No, your assumption is incorrect. Standard No. 108 permits the upper beam of a headlamp to be provided by two light sources and thus does not prohibit use of your design. However, regardless whether the upper beam is provided by one or two light sources, the maximum intensity limits for upper beams at test points H-V and 4D-V must not be exceeded. These values appear in the photometric Figures that Standard No. 108 has adopted for various types of headlighting systems.

Sincerely,

John Womack
Acting Chief Counsel
ref:108
d.4/10/01