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Interpretation ID: 24524.ztv

D.W. Robertson, Captain
Commonwealth of Virginia
Department of State Police
491 Southlake Boulevard
Richmond, VA 23236

Dear Captain Robertson:

This is in reply to your letter of May 20, 2002, to Taylor Vinson of this Office, which we received on June 3. The subject of your letter was "road lamps."

Specifically, you reported that the 2001 and 2002 model year Acura CL coupes are equipped with "road lamps." You stated that "these lamps are not marked, and from my understanding do not fall under FMVSS 108. These lamps produce 5 watts of power, and the lens and reflector are not specifically focused to any point." You related that "Honda advised that these lamps are located below the headlights . . . and are used in conjunction with both the low beam and high beam headlamps . . . ."

You asked two questions: "1. Are road lamps, as described, sanctioned by FMVSS 108?," and "2. If they are not sanctioned by FMVSS 108, are they sanctioned by NHTSA in some other rule or regulation?"

The lamps you describe are not required by FMVSS No. 108. The question then arises whether lamps other than required lamps are allowed. FMVSS No. 108 permits a new vehicle to be manufactured and/or sold with supplementary lamps, subject to the prohibition imposed by S5.1.3 of the standard that "No additional lamp, reflective device, or other item of motor vehicle equipment shall be installed that impairs the effectiveness of lighting equipment required by this standard."

We have not tested Acura vehicles to judge whether additional lamps of 5 watts located below the headlamps in the front bumper, and operating in conjunction with them, will impair the effectiveness of the upper or lower beam headlamps, or of the front turn signal, parking, or hazard warning system lamps. The label that Honda affixes to each Acura CL coupe certifying that the vehicle complies with all applicable FMVSS represents, in part, its determination that the road lamps do not impair the effectiveness of other front lighting equipment within the meaning of S5.1.3. We have no basis to question that determination.

As for your second question, "road lamps" are motor vehicle equipment and subject to the agencys safety notification and remedy requirements if a safety-related defect occurs in them. Apart from regulations implementing these requirements, there are no other NHTSA regulations that pertain to auxiliary lighting equipment such as road lamps. This means that any State may regulate these lamps, and their use, as appears appropriate to the State.

If you have any further concerns, please call Taylor Vinson at 202-366-5263.

Jacqueline Glassman
Chief Counsel