Mr. Takashi Adachi
Manager
Ichikoh Industries, Ltd.
North American Liaison Office
555 Briarwood Circle, Suite 190
Ann Arbor, MI 48108

Dear Mr. Adachi:

This is in reply to your letter of March 14, 1995, to Richard Van Iderstine of this agency, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it applies to a reflex reflector design that you attached. This design shows a single reflector 2 inches in height mounted behind a clear outer lens which is bisected horizontally by an opaque strip 6mm (.25 in.) wide, giving the impression from the exterior of two reflectors, one .75 in. high above the divider, and one that is 1.00 in. in height, below the divider.

You have asked whether the "structure of the reflex reflector conforms to FMVSS 108," and whether photometric conformance is judged with respect to the single reflector crossed by the opaque strip, or whether both the upper and lower portions of the bisected reflector must meet the photometric specification.

Standard No. 108 is a performance standard, not a design standard. The standard does not specify any requirements concerning the structure of reflectors. The applicable requirements for reflex reflectors are those of SAE Standard J594f Reflex Reflectors January 1977, which Standard No. 108 incorporates by reference. Your reflector should be tested as a single reflector according to the procedures set forth in J594f. If the reflector does not meet the photometric performance requirements of that standard, you may add sufficient reflective elements to the reflector design until conformance is achieved. There is no need to test the upper and lower portions as separate reflectors.

If you have any further questions, you may refer them to Taylor Vinson (202) 366-5263 of this Office.

Sincerely,

John Womack Acting Chief Counsel ref:108 d:5/9/95