|This document retrieved from the NHTSA
legal interpretations database.
Mr. Tadashi Suzuki
Manager, Regulation & Homologation
Stanley Electric Co., Ltd.
2-9-13, Nakameguro, Meguro-ku
Dear Mr. Suzuki:
This is in reply to your letter of March 12, 2001, asking for an
interpretation of S7.8.5 of Federal Motor Vehicle Safety Standard No. 108.
S7.8.5 specifies that "When activated in a steady-burning state,
headlamps shall not have any styling ornament or other feature, such as a
translucent cover or grill, in front of the lens." This prohibition
was developed when the only headlamps available were sealed beam units.
You state that the majority of headlamps today are individually designed
for specific vehicles and you believe that the performance of these
headlamps can be controlled so that if they have additional parts, the
headlamp designer has complete control over them. Therefore "banning
of styling parts for all kinds of headlamps has no meaning to
safety." For this reason, you "believe S7.8.5 is not applicable
to headlamps designed for specific vehicle models."
We do not agree with your interpretation. S7.8.5 contains no qualifying
language; it applies to all headlamps. However, S7.8.5 does not prohibit
use of a "styling ornament or other feature" in the lens itself,
or behind the lens, if the headlamp with these features is certified as
complying with Standard No. 108.
We also call your attention to S5.1.3 which, in effect, prohibits
additional motor vehicle equipment that impairs the effectiveness of
lighting equipment required by Standard No. 108. Any styling feature or
other part of a motor vehicle that is in front of the lens of a headlamp
in use has the potential to impair the light output of the lamp. Even if
there is no impairment initially, grills and covers prevent the lamps from
being cleaned. Covers themselves are susceptible to accumulations of dirt
and moisture on their inner surface. These accumulations on the outer
surface of the headlamp lens can cause glare and reduction in roadway
illumination (S5.1.3 would also
prohibit, as original equipment, covers over required lighting equipment
other than headlamps, for the same reason of impairment). While our
laws do not prohibit the sale of lamp covers in the aftermarket, their
installation would create a noncompliance with Standard No. 108. In
that instance, there would be a violation of 49 U.S.C. 30122(b) if the
covers were installed by a manufacturer, dealer, distributor, or motor
vehicle repair business.
Acting Chief Counsel