Interpretation ID: nht79-2.40

DATE: 05/15/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Stanley Electric Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 28, 1979, asking two questions with respect to certification of lighting equipment by use of the DOT symbol, as permitted by S4.7.2 of Federal Motor Vehicle Safety Standard No. 108.

Your first question is whether disassembled parts such as lenses, screws, or bulbs must also be certified as conforming to all applicable Federal motor vehicle safety standards. The answer is no; only the completed lamp assembly must be so certified.

You have also asked "in the case of lamp lens incorporated with reflex reflector do we have to label the DOT label on this reflex reflector certifying it meets FMVSS?" The answer is yes. Although the lamp lens is not a required equipment item and not certified since it is only part of a lamp, the reflex reflector incorporated in it must be certified since the reflector is an item required by Standard No. 108.

I hope this answers your questions.

SINCERELY,

STANLEY ELECTRIC CO., LTD.

April 28, 1979

U.S. Department of Transportation National Highway Traffic Safety Administration

Dear Sirs,

According to your National Traffic and Motor Vehicle Safety Act of 1966, Sec. 114 a motor vehicle or motor vehicle equipment to which FMVSS applies is required to be certified that it conforms to FMVSS. In the case of an item or motor vehicle equipment such certification may be in the form of a label or tag on such item or on the outside of a container in which such item is delivered.

And from FMVSS No.108, Sec. 4.7.2. the symbol DOT may be labeled which shall constitute a certification that it conforms to FMVSS 108.

We are now labelling the DOT labels on our lamp assemblies, lamp units and reflex reflector assemblies of motor vehicle equipment for replacement.

The motor vehicle lighting equipments for replacement, however, are now delivered not only in the form of ass'y or unit but also in the form of disassembled parts such as for example, lenses, screws and bulbs, etc. Is it necessary for these parts also to be certified that they conform to FMVSS?

Also, in the case of lamp lens incorporated with reflex reflector do we have to label the DOT label on this reflex reflector certifing it meets FMVSS?

We would appreciate very much having your comments on our above questions at your earliest convenience.

Thanking you in advance for your cooperation,

H. Miyazawa Director, Automotive Lighting Engineering Dept.