Interpretation ID: nht94-5.50

DATE: May 5, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Tilman Spingler -- Robert Bosch GmbH

TITLE: None

ATTACHMT: Attached to letter dated 3/25/94 from Tilman Spingler to John Womack (OCC-9889)

TEXT:

This responds to your letter of March 25, 1994, asking for an interpretation of Motor Vehicle Safety Standard No. 108 with respect to integral beam headlighting systems.

You reference a letter of this office to Toyota in which we permit location of the light source control module outside the headlamp housing but permanently attached to it by a cable. You have asked whether there are "requirements for this cable concerning indivisibility and integration...."

There are no such requirements for the cable in Standard No. 108, and the headlamp manufacturer may adopt the construction that it has determined is most suitable for its design.