Mr. Robert E. Hunter
President
Automotive Repair Corporation
P.O. Box 1542
Airway Heights, WA. 99041

Dear Mr. Hunter:

We have received your FAX of March 4 , 1996, to John Womack of this Office asking for advice "as to the procedure for initiating the approval process for [ a multi-functional turn signal device] this device for the OEM and after markets."

There are no laws that require Federal approval of motor vehicle lighting equipment before it is offered to the public. A manufacturer of replacement lighting equipment must ensure that its product complies with any applicable requirement of Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment , and certify such compliance, before offering the item for sale. The manufacturer may certify, either by a DOT symbol on the item itself, or by a statement of compliance attached to the item or to the carton in which it is shipped. If the item is offered as original equipment, the manufacturer of the vehicle on which it is installed is responsible for certification that the vehicle as equipped with all lighting devices is in conformance with Standard No. 108.

Standard No. 108 requires motor vehicles to be equipped with turn signal lamps meeting the requirements of SAE Standard J588 NOV84, a turn signal operating unit in conformance with SAE Standard J589, April 1964, and a turn signal flasher complying with SAE J590b October 1965. However, if the vehicle's overall width is 80 or more inches, the turn signal lamps must meet the requirements of SAE Standard J1385 APR85.

If you review these SAE materials and have specific questions about how they relate to your device, you may call Taylor Vinson of this Office (202-366-5263).

Sincerely,

Samuel J. Dubbin Chief Counsel ref:108 d:3/28/96