Mr. Junichi Hasegawa

Manager

Quality and Assurance Department

Stanley Electric Co., Ltd.

400 Soya, Hadano-shi

Kanagawa 257-8555

Japan

 

Dear Mr. Hasegawa:

 

This letter is in response to your October 17, 2011 letter inquiring whether certain light-emitting diode (LED) headlamp configurations installed on motorcycles would comply with Federal Motor Vehicle Safety Standard  No. 108, Lamps, Reflective Devices, and Associated Equipment.  We apologize for the delay in our response.  Below we explain how our lighting regulations apply to LED headlamps installed on motorcycles.

 

By way of background, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards that set performance requirements for new motor vehicles and items of motor vehicle equipment (see 49 U.S.C. Chapter 301).  NHTSA does not provide approval of motor vehicles or motor vehicle equipment, and we do not determine compliance of a vehicle or item of motor vehicle equipment outside the context of an actual enforcement proceeding.  Instead, manufacturers are required to self-certify that their products conform to all applicable safety standards that are in effect on the date of manufacture.  The following represents our opinion regarding the applicability of our regulations to your proposed lighting configuration based upon the facts set forth in the materials that you submitted.

 

In your letter, you raise 3 basic questions regarding LED headlamps for motorcycles, as follows:

 

1)      Are LED headlamps allowed for motor vehicles other than motorcycles?

2)      Are LED headlamps allowed for motorcycles, depending on their layout?

3)      Is the out-of-focus test required for LED headlamps installed on motorcycles?

 

We will answer these questions in turn below.

 

1)      Are LED headlamps allowed for motor vehicles other than motorcycles?

 

In your letter, you state that a prior interpretation by NHTSA confirms that LED headlamps are permissible for motor vehicles other than motorcycles because they may be regarded as an “integral beam” head lighting system as specified in S10.14 of FMVSS No. 108.  An integral beam headlamp is defined in S4 as "a headlamp (other than a standardized sealed beam headlamp designed to conform to paragraph S10.13 or a replaceable bulb headlamp designed to conform to paragraph S10.15) comprising an integral and indivisible optical assembly including lens, reflector, and light source, except that a headlamp conforming to paragraph S10.18.8 or paragraph S10.18.9 may have a lens designed to be replaceable." We have stated that we would consider an LED headlamp meeting the above definition to be an integral beam headlamp if the LEDs are wired in series so that a failure of one LED would cause all the LEDs to cease functioning.[1]  As we stated previously, the LEDs must be wired in series for the headlamps to conform to the installation requirements in S6.1.3.5 which correspond to whether each lamp is comprised of one or two light sources.  Because LED headlamps can qualify as integral beam head lighting systems, these systems would comply with FMVSS No. 108 if installed on motor vehicles other than motorcycles.

 

2)      Are LED headlamps allowed for motorcycles, depending on their layout?

 

Paragraph S10.17 of FMVSS No. 108 specifies that headlamps installed on motorcycles:

 

[M]ay consist of: (a) one half of any headlighting system of Table II which provides both a full upper beam and full lower beam, and is designed to conform to the requirements for that headlamp type. Where more than one lamp must be used, the lamps shall be mounted vertically, with the lower beam as high as practicable, or (b) a headlighting system designed to conform to the requirements of paragraphs S10.17.1 through S10.17.5.  49 C.F.R. § 571.108

 

If an LED headlamp installed on a motorcycle is not half of a head lighting system installed on a four wheeled vehicle, in addition to the other requirements contained in S10.17, it must meet the out-of-focus test in S14.3[2] and the photometry requirements in Table XX.  Because we have stated that an LED headlamp can be treated as an integral beam headlamp provided the conditions above are met, an LED headlamp system consisting of one-half of an integral beam system meeting the requirements of paragraph S10.14 could be installed on a motorcycle.

 

You describe three different “typical” configurations for potential LED motorcycle headlamps and ask whether any of these would be permissible.  The first configuration you describe consists of a single headlamp with both an upper and a lower beam contained in a single housing behind a single lens and symmetrically disposed about the vertical centerline.  The second configuration consists of two headlamps symmetrically disposed about the vertical centerline, one of which provides a lower beam and one of which provides an upper beam.  The third configuration consists of two headlamps symmetrically disposed about the vertical centerline each of which provides both an upper and lower beam. 

 

Because paragraph S10.17(a) specifies that a headlamp system installed on a motorcycle must consist of half of a full system that would be installed on a four wheeled vehicle, a headlamp installed on a motorcycle would only be able to comply with this paragraph if it consisted of a single upper beam and a single lower beam.  Therefore, under paragraph S10.17(a), a motorcycle could be equipped with a single LED headlamp containing both an upper and lower beam (like your first configuration), or it could be equipped with an LED headlamp system consisting of two headlamps, one of which provided a lower beam and one of which provided an upper beam (like your second configuration), assuming all other applicable requirements were met. 

 

We note that in order for a motorcycle headlamp system with two headlamps to be tested as half of a headlamp system installed on a four wheeled vehicle under S10.17(a), the lamps must be mounted vertically with the lower beam as high as practicable.  The headlamp layout in your second configuration does not comply with this requirement because the lamps are horizontally disposed about the vertical centerline.  Thus, if this layout was used, the lamps would have to comply with S10.17(b).

 

A head lighting system installed on a motorcycle with two lower and two upper beams (like your third configuration) would not comply with paragraph S10.17(a).  A configuration like your third example, whether LED or not, would thus have to comply with the requirements for motorcycle headlamps in order to be permissible as a motorcycle headlamp configuration under S10.17(b).  Additionally, your third configuration would not conform to paragraph S6.1.3.5.1.2 (applicable to all vehicles) which requires that headlamps with two vertically oriented light sources be installed so that the lower beam is provided by the uppermost light source.

 

3)      Is the out-of-focus test required for LED headlamps installed on motorcycles?

 

As discussed above, your first configuration could potentially qualify under S10.17(a) as half of a full system that would be installed on a four wheeled vehicle.  If a motorcycle headlamp configuration meets the requirements of S10.17(a), it is not subject to the out-of-focus test.  If a motorcycle headlamp configuration seeks to meet the requirements of S10.17(b) instead, as your second, and third configurations might, it would need to comply with all of the requirements of S10.17.4, including the out-of-focus test.

 

If you have further questions, you may refer them to Thomas Healy of this office (202-366-2992).

 

Sincerely,

 

 

                       

                                                                        O. Kevin Vincent

                                                                        Chief Counsel

 

Dated: 4/8/13

Standard No. 108



[1] Letter from Stephen Wood, Acting Chief Counsel, NHTSA, to Takayuki Amma, Manager, Koito Manufacturing Co. (Dec. 21, 2005), available at http://isearch.nhtsa.gov/files/LEDlamp.1.html.

[2] The requirements for the out-of-focus test previously incorporated by reference from SAE J584 are now contained in S14.3 of FMVSS No. 108.