Interpretation ID: aiam3506
Wonder Enterprise
2955 S.W. 15 Street
Miami
FL 33145;
Dear Mr. Munoz: This is in reply to your letter of November 22, 1982, asking whethe Federal regulations would prohibit use of your patented device, the 'Illuminated Wonder Panel.' This device would be used in the space provided for the front license plate and consists of a panel on which numbers or letters would be illuminated from behind, if an owner wished to 'personalize' his vehicle. You have indicated that the candela for each character averages .0365, and that with a seven character maximum, a total output of less than .25 candela would result. You submitted photographs showing this device in operation from a distance of 50 feet on a vehicle using parking lamps only, and using parking lamps/low beam headlamps.; Your device is not directly regulated by the Federal motor vehicl safety standard on vehicle lighting, Standard No. 108 (sic) As an item of original equipment, your device is permissible unless it impairs the effectiveness of lighting equipment required by the standard, such as parking lamps and headlamps. Judging by the photographs you submitted, it does not appear that your device would impair the effectiveness of other lighting equipment. As an aftermarket item, your device is subject to regulation by any State in which the vehicle bearing it is registered. You will have to consult these States for further advice.; We hope that this is responsive to your request. Sincerely, Frank Berndt, Chief Counsel