Interpretation ID: aiam3639
Automobile Importers of America
Inc.
1735 Jefferson Davis Highway
Suite 1002
Arlington
VA 22202;
Dear Mr. Henderson: This responds to your letter asking about the identificatio requirements of FMVSS 101, *Controls and Displays*. You asked whether it is permissible for a manufacturer to identify a certain manual control with the symbol specified by the European Economic Community (EEC) for the cold start control. According to your letter, the control resets injection timing *and* actuates cylinder warming.; By way of background information, the agency does not provide approval of motor vehicles or motor vehicle equipment. The Vehicle Safety Act requires that each manufacturer assure that its products are in compliance with all applicable standards. The following only represents the agency's opinion based on the specific facts provided in your letter.; The answer to your question is yes, since Standard No. 101 does no include any identification requirements applicable to that specific type of control.; Section S5 of Standard No. 101 requires each passenger car manufacture with any control listed in S5.1 or in column 1 of Table I to meet the requirements of the standard for the location, identification and illumination of such control.; Neither section S5.1 nor column 1 of Table I list or include a singl control which operates the *two* functions noted above.; Since Standard No. 101 does not include any identification requirement applicable to that type of control, identification is at the discretion of the manufacturer. It is therefore permissible, under that standard, to identify that type of control with the symbol specified by the EEC.; Sincerely, Frank Berndt, Chief Counsel