Interpretation ID: aiam2503
Nissan Motor Co.
Ltd.
P.O. Box 1606
Englewood Cliffs
N.J. 07632;
Dear Mr. Iinuma: This responds to your January 6, 1977, question regarding the effectiv date of the recent amendment to Standard No. 116, *Motor Vehicle Brake Fluids*, That specifies color coding requirements for brake fluids (41 FR 54942, December 16, 1976). You asked whether motor vehicles manufactured after the effective date for the color coding requirements (September 1, 1978) may be equipped with brake fluids manufactured prior to that date that do not conform to the color coding requirements. The answer to your question is yes. Paragraph S5.3 of Standard No. 116 specifies that motor vehicles having hydraulic brake systems shall be equipped with brake fluid that has been manufactured and packaged in conformity with the requirements of the standard. The agency interprets this to mean that vehicles shall be equipped with any brake fluid that conformed to the requirements of Standard No. 116 at the time the brake fluid was manufactured.; Sincerely, Frank Berndt, Acting Chief Counsel