Interpretation ID: 2414y
Dept K2/ELE2
Robert Bosch GmbH
Postfach 42
7410 Reutlingen
W. Germany
Dear Ms Schmock:
This is in reply to your FAX of March 6, l990, with respect to the relationship between Federal Motor Vehicle Safety Standard No. l08, and "CAC Title 13, Article 9".
You have indicated that CAC requires a headlamp adjustment range in the horizontal of at least +/- 4 degrees, whereas Standard No. l08 requires a horizontal adjustment range of not less than 2.5 degrees. You have asked whether Bosch headlamps still must have an adjustment range of +/-4 degrees in the horizontal although Standard No. l08 has been changed.
We understand that "CAC" refers to "California Administrative Code". The effect of the preemption provisions of the National Traffic and Motor Vehicle Safety Act is to prohibit California from adopting and enforcing a minimum horizontal headlamp adjustment range greater or less than 2.5 degrees. Thus, a State requirement that a headlamp have a horizontal range of +/- 4 degrees is invalid because it differs from a corresponding Federal requirement.
We are unable to answer your further questions with respect to the California code, and suggest that, for further information you write Department of Motor Vehicles, State of California, 2415 First Avenue, Sacramento, California 95818, ATTN: Mr. A. A. Pierce, Director (FAX 916-732-7854).
Sincerely,
Stephen P. Wood Acting Chief Counsel
ref:l08 d:4/25/90