Interpretation ID: aiam2809

Mr. William Shapiro, Manager, Regulatory Affairs, Product Planning and Development, Volvo of America Corporation, Rockleigh, NJ 07647; Mr. William Shapiro
Manager
Regulatory Affairs
Product Planning and Development
Volvo of America Corporation
Rockleigh
NJ 07647;

Dear Mr. Shapiro: This is in reply to your letter of May 3, 1978 asking whether there i any legal objection to Volvo's installation of red rear fog lamps on passenger cars it sells in the United States.; As you have noted, 'the only possible objection' to these lamps is th prohibition of S4.1.3 of Motor Vehicle Safety Standard No. 108 against the installation of lamps that impair the effectiveness of lighting equipment mandated by the standard. We have no basis for disagreeing with your opinion that the red 'rear fog lamps do not impair the effectiveness of other lighting equipment.' However, the lamps would be subject to the laws of the individual States.; Sincerely, Joseph J. Levin, Jr., Chief Counsel