Mr. Jeff Deetz
Santeca Electronics, Inc.
7215 East 21st Street
Indianapolis, IN 46219
Dear Mr. Deetz:
This is in reply to your letter of July 30, 2002, to John Womack of this office with respect to a High Intensity Discharge (HID) light source conversion kit that you wish to sell for replaceable bulb headlamps in the United States. On August 15, Taylor Vinson of this office e-mailed you to request a sample of the kit so that we might be better able to advise you. The kit arrived on September 12.
Your specific request was "for guidance in how to begin the process of obtaining D.O.T. approval" for your kit. We have no authority either to approve or disapprove motor vehicles or items of motor vehicle equipment. We do advise correspondents of the relationship of their products to applicable Federal motor vehicle safety standards (FMVSS) and other regulations that we administer. If a manufacturer determines that its product is covered by one or more of the FMVSS, and that its product complies with all applicable FMVSS, it must certify compliance of the product when the product is offered for sale. The symbol "DOT" on replacement lighting equipment is often mistaken for "DOT approval" of the equipment but, in fact, it is the manufacturer’s own certification of compliance.
Because your HID conversion kit is intended to replace certain original headlighting equipment, the kit is subject to paragraph S5.8, Replacement Equipment, of FMVSS No. 108 Lamps, Reflective Devices and Associated Equipment, 49 CFR 571.108. Paragraph S5.8 requires that any motor vehicle replacement replaceable light source that is offered for sale in the United States comply with the requirements of FMVSS No. 108. The Federal specifications for replaceable light sources used in original equipment motor vehicle headlighting systems are located in 49 CFR Part 564, Replaceable Light Source Information. The purpose for storing the specifications in Part 564 is two fold: (1) to ensure the availability to replacement light source manufacturers of the specifications of original equipment light sources such that replacement light sources are interchangeable with original equipment light sources and provide equivalent performance, and (2) that redesigned or newly developed light sources are designated as distinct, different, and noninterchangeable with previously existing light sources.
Paragraph S7.7, Replaceable light sources, of FMVSS No. 108, requires in part that each replaceable light source be designed to conform to the dimensions and electrical specifications furnished with respect to it pursuant to Part 564. Thus, in order to use a replaceable light source in a replaceable bulb headlamp, a manufacturer must first have submitted certain information with respect to it (and its ballast if required) in Part 564, or it may use a light source (and ballast if required) if its specifications are already filed in Part 564.
The kit that you furnished us appears to be designed to replace an H1 replaceable light source, and consists of two parts marketed under the name "Thunder Beam." The first part is labeled "HID Bulb Set" and contains two replaceable light sources, identified on the packaging as "WB-H1." The second part is labeled "HID Driver Unit TD-5000," and contains a ballast, an ignitor, a relay, and adapters to convert the motor vehicle’s wiring harness to be compatible with the HID conversion kit.
Based on a review of the H1 light source specification filed in the Part 564 docket (#3397), it is apparent that the Thunder Beam HID Conversion kit is a significant redesign of the H1 light source. At the most basic level, an H1 light source incorporates an incandescent filament in which light is produced by a metallic wire coil heated to incandescence by an electrical current, whereas the HID conversion kit’s light source incorporates a discharge arc to produce the light and requires a ballast for operation. Thus, in order to comply with paragraph S7.7 of FMVSS No. 108, the Thunder Beam light source must comply with, inter alia, the dimensional specifications for the metallic wire coil filament size and location, the electrical connector size and location, and the ballast would need to be a design currently on file for use with an H1 light source. Complying with the dimensional aspects of the H1 light source appears to be an impossibility considering that the wire coil filament and the electrical connector are not a part of your design. Furthermore, there are no ballast designs on file for use with an H1 light source. Thus, your company’s HID conversion kit is not a design that conforms to the Standard and could not be certified as complying with FMVSS No. 108, nor imported into or sold in the United States.
This interpretation would apply to any HID replaceable light source whose base was modified or manufactured to be interchangeable with any regulated headlamp replaceable light source that incorporates an incandescent filament design.
If you have any questions regarding how a manufacturer may submit information to Part 564, you may contact Michael Cole of our Office of Rulemaking (202-366-5276). For legal questions, you may phone Taylor Vinson of this Office (202-366-5263).