Interpretation ID: nht94-5.1

TYPE: INTERPRETATION-NHTSA

DATE: December 7, 1994

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Herr P. Binder -- ITT Automotive europe

TITLE: None

ATTACHMT: ATTACHED TO LETTER DATED 11/22/94 FROM P. BINDER TO JOHN WOMACK (OCC 10510)

TEXT: This responds to your FAX of November 21, 1994, to John Womack of this Office.

You inquire with respect to a yellow bulb intended for use as both original and replacement equipment in a rear turn signal lamp for a passenger car. The bulb complies with ECE specifications. You have asked the following questions:

"1) Is it allowed in USA that new rearlamps are fitted with such 'Europe' - bulbs?"

Yes. Bulbs other than those specified by SAE J573 are considered "special bulbs" and are permitted by Note 3 at the end of Standard No. 108 as long as the lamp assemblies in which they are used conform to all applicable requirements of Standard No. 108.

"2) Do spare bulbs of the same type (PY 21W) have to be freely available in USA (e.g. supermarket, station, etc.)?"

There is no legal requirement that replacement bulbs be freely available. For reasons of safety, NHTSA encourages wide distribution of replacement parts of all sorts.

"3) Would it be sufficient if the car manufacturer offers this bulb (PY 21W) as a spare part within his service stations in USA?"

The determination of the distribution of replacement bulbs is a decision to be made by the car manufacturer.

"4) Is there any specification or law regarding the use of bulbs in USA? If so, please inform us about these specifications."

Although not directly incorporated by reference in Standard No. 108, NHTSA regards SAE Standards J567 "Lamp Bulb Retention System" and J573 "Lamp Bulbs and Sealed Units" as appropriate specifications for bulbs and their sockets used in motor vehicle lamp s other than headlamps. However, as indicated above, Note 3 permits the use of bulbs other than these.

"5) Is the use of bulbs treated differently in the single states?"

We have no information that any state treats the use of bulbs differently. Questions regarding the laws of the individual states are answered by the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203, and yo u may wish to consult them for an opinion.