Interpretation ID: aiam2498
Market Research Analyst
Robert Bosch Corporation
2800 South 25th Avenue
Broadview
IL 60153;
Dear Mr. Cheshire: This is in response to your letter of January 26, 1977, asking fo confirmation of several interpretations of Federal Motor Vehicle Safety Standard No. 108 *Lamps, Reflective Devices, and Associated Equipment*.; You are correct that, as an equipment standard, Standard No. 10 applies only to replacement of equipment that was originally mounted on the vehicle to enable it to comply with the requirements of the standard. It does not apply to items not covered by the standard, but which are frequently provided as new vehicle options, such as fog lamps and cornerning (sic) lamps. Any item of lighting equipment not required is permissable (sic) to be installed, as you also noted, if it does not impair the effectiveness of the required lighting equipment (paragraph S4.1.3). Additional lighting equipment is otherwise subject to State regulation.; You also asked 'what would be the NHTSA's stand on products where SA standards do not exist, for example halogen headlights?' A halogen headlamp that does not comply with Standard No. 108 and is intended as a replacement headlamp may not be imported and sold for this use. On the other hand, halogen fog lamps may be imported and sold, subject to State regulations.; I hope this answers your questions. Yours truly, Frank Berndt, Acting Chief Counsel