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.
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
(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