Interpretation ID: aiam3793
1300 California Drive
Rolla
MO 65401;
Dear Mr. White: This is in response to your January 3, 1984, letter to Roger Fairchil of this office regarding Federal Motor Vehicle Safety Standard No. 111 (Rearview Mirror Systems). You have requested information on the applicability of that standard, particularly in regard to aftermarket mirrors.; FMVSS 111 is a rule or regulation (the terms are generally use interchangeably) establishing requirements for rearview mirrors on new passenger cars, multipurpose passenger vehicles, trucks, buses, school buses, and motorcycles. Aftermarket mirror manufacturers do not have to certify compliance with our standards. However, the addition of an aftermarket mirror to a motor vehicle may be subject to certain legal requirements. Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act prohibits any manufacturer, distributor, or dealer of motor vehicles or motor vehicle equipment, or any motor vehicle repair business from knowingly rendering inoperative any device or element of design installed on a vehicle in compliance with a safety standard. Thus, manufacturers, distributors, dealers, and repair businesses cannot remove a rearview mirror installed as original equipment in compliance with our standard and replace that mirror with a noncomplying aftermarket mirror. Replacement by other individuals or organizations or replacement with a complying aftermarket mirror would be permitted.; With regard to your final question as to requirements applicable to th use of non-glare glass in mirrors, this agency issued on November 6, 1978, a notice of proposed rulemaking on possible upgrading of rearview mirror requirements (copy enclosed). One part of this proposal would establish image luminance criteria for rearview mirrors. The agency has not yet determined whether this requirement should be implemented, and no action is imminent on that proposal.; Sincerely, Frank Berndt, Chief Counsel