Mr. Tadashi Suzuki
Manager, Regulation & Homologation
Stanley Electric Co., Ltd.
2-9-13, Nakameguro, Meguro-ku
Tokyo 153-8636
Japan

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.

Sincerely,

John Womack
Acting Chief Counsel

ref:108
d.5/9/01