Interpretation ID: nht89-2.7

TYPE: INTERPRETATION-NHTSA

DATE: 06/19/89

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: M. IWASE, -- TECHNICAL INFORMATION DEPT. KOITO MFG. CO., LTD.

TITLE: NONE

ATTACHMT: LETTER DATED 03/20/89 FROM M. IWASE TO ERIKA Z. JONES -- NHTSA

TEXT: Dear Mr. Iwase:

This is in reply to your letter of March 20, 1989, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it applies to the location of the license plate lamp on motor vehicles.

You noted the language in Tables II and IV of Standard No. 108 specifying that the lamp is to be located "at rear license plate, to illuminate the plate from the top or sides," for, vehicles other than motorcycles. The requirement for motorcycles (Table IV) is simply that it be located "at rear license plate." You have asked for confirmation that, except on motorcycles, the license plate lamp shall not illuminate the plate from the bottom.

Your interpretation is correct. The rationale for the requirement is that in a location other than at the bottom, the license plate lamp is less likely to be obstructed by snow or mud.

I hope that this answers your question.

Sincerely,