Interpretation ID: nht89-1.1

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/89 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: MARK JANSEN -- CHEVY DUTY PICKUP PARTS

ATTACHMT: LETTER DATED 11-03-88 TO M.J. MIZEJEWSKI, FOREIGN MARKETING SPECIALISTS, INC., FROM E.Z. JONES, CHIEF COUNSEL, NHTSA

TEXT: This is in reply to your letter of September 17, 1988, to Taylor Vinson of this Office. You would like to have parking lamp and tail lamp lenses "remanufactured" for use on 1947-66 Chevrolet and GMC pickup trucks, and have requested our views.

We assume that you wish to have lenses manufactured to replace original equipment lenses on the trucks produced in the years indicated. Essentially, your operation appears unaffected by the requirements of this Department. The Federal motor vehicle lig hting standard applies only to lenses intended to replace original lenses on vehicles manufactured on and after January 1, 1972, and would not cover lenses for use on 1947-66 trucks. However, if the lenses you intend to manufacture are interchangeable w ith those on vehicles manufactured on and after January 1, 1972, you may have an obligation to ensure that they meet Federal requirements. If this is the case, we would be pleased to advise you further.

Notwithstanding the foregoing, all replacement lenses are equipment that is subject to Federal notification and remedy provisions if they incorporate a defect that relates to motor vehicle safety. In your case, this likelihood may be remote as the item concerned is a simple one, but attention should be paid to quality control.