Interpretation ID: 0437

Mr. Bryan J Williams
Director, International Operations
Red Spot Paint & Varnish Co Inc.
1111 East Louisiana Street
Evansville, IN 47711

FAX 812-467-2388

Dear Mr. Williams:

This is in reply to your FAX of October 24, 1994, to Taylor Vinson of this Office requesting an interpretation regarding the relationship of Motor Vehicle Safety Standard No. 108 to an AAMVA list.

Your company manufactures UV coatings for polycarbonate headlamp lenses. These "provide abrasion resistance properties as well as protecting the plastic lens from the deleterious effects of outdoor exposure." One of these coatings, UVT200, is used by Ford, General Motors, and Chrysler on headlamp lenses. However, "UVT200 does not appear on the American Association of Motor Vehicle Administrators (AAMVA) 'Listing of Acceptable Plastics for Optical Lenses and Reflectors Used on Motor Vehicles.'" You inform us that some overseas headlamp manufacturers believe that appearance on the list is required by Federal law and is a prerequisite to certification. The question you ask is:

Must a coating for plastic (polycarbonate) headlamp lenses appear on the AAMVA "Listing . . ." in order to meet the requirements of FMVSS 108?

The answer is no. Paragraph S5.1.2 of Standard No. 108 requires that plastic materials used in lenses (which include headlamp lenses) conform to SAE Recommended Practice J576c, Plastic Materials for Use in Optical Parts, Such as Lenses and Reflectors of Motor Vehicle Lighting Devices, May 1970. Under SAE J576c's outdoor exposure test, the luminous transmittance of the material must not change by more than 25% from its performance before the test. In appearance, the headlamp lens material must not show surface deterioration, crazing, dimensional changes, or delamination. Also, under paragraph S5.1.2(b), after the outdoor exposure test, the haze and surface luster of the material must not be greater than 30

percent haze, as measured by ASTM D-1003-61. Manufacturers have found that a coating is required for the plastics used in headlamp lenses to meet Standard No. 108's outdoor exposure requirements. However, neither SAE J576c or Standard No. 108 require the coating, let alone specify what coating is acceptable. The decision to coat, and the choice of coating, is that of the manufacturer in determining compliance with and certification to Standard No. 108. Therefore, the AAMVA list has no legal relationship to Standard No. 108 and it is immaterial to NHTSA whether the coating used is or is not on the AAMVA list.

Sincerely,

Philip R. Recht Chief Counsel ref:108 d:12/7/94