Interpretation ID: 2631o

Mr. M. Arisaka Manager, Automotive Lighting Engineering Sect. Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, Japan

Dear Mr. Arisaka:

This is in reply to your letter of October 8, 1987, with reference to a newly developed lamp bulb "for automotive light-signalling devices." You state that the lamp has a bulb defined in SAE J387 and that its specifications for bulb and base meet those of SAE J573. The candlepower of the new lamp bulb is said to be 40% higher than that of a conventional bulb. You have asked whether you can "use the device with this new lamp bulb" in the United States.

For lamps other than replaceable bulb headlamps Federal Motor Vehicle Safety Standard No. l08 establishes requirements for photometric performance, and not for bulbs. Therefore, SAE J387 and J573 are not incorporated into Standard No. l08. Any motor vehicle turn signal or hazard warning signal device using Stanley's new high-candlepower bulb would appear to be permissible as long as it meets the applicable photometric specifications of Standard No. l08, and does not exceed any maxima of these specifications.

Sincerely,

Erika Z. Jones Chief Counsel ref:l08 d:l2/3l/87