Interpretation ID: nht87-1.14

TYPE: INTERPRETATION-NHTSA

DATE: 01/12/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Lynn Walker -- Sales Manager, Panamasia West Coast, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Lynn Walker Sales Manager Panamasia West Coast, Inc. 16205 Distribution Way Cerritos, CA 90701

This is in reply to your letter of September 17, 1986, to Mr. Vinson this office asking whether a lamp you wish to import "is legal for highway use in the U.S." The lamp is an aftermarket auxiliary turn signal that is mounted on top of each front fender. The lens is green, but could be any color that is legal for highway use. The lens is visible "from all directions" but could be designed so that it is visible only to the rear, i.e. to the driver.

Federal motor vehicle lighting requirements do not currently apply to aftermarket lamps of this nature. Whether the lamp is legal, therefore, is a question to be answered under the laws of each State in which it will be sold and operated. While we are no t familiar with State lighting laws you nay find that there is a greater likelihood that the auxiliary turn signal lamp will be acceptable if it has a yellow lens, or if its green lens is visible only to the driver.

I hope that this is helpful to you.

Sincerely,

Erika Z. Jones Chief Counsel

PANAMASIA WEST COAST, INC. 16205 Distribution Way Cerritos, CA 90701 (213) 926-5591

Sept. 17, 1986

Dear Mr. Vinson,

We are an Import-Export Company specializing in Automotive Parts and Accessories.

We are interested in importing the automotive lamp which is described on the following page.

We wish to know if this type of lamp is legal for highway use in the U.S. If any alterations are necessary to make this lamp legal, please advise us of them.

If we can give you more information please don't hesitate to contact us at the above address or telephone number.

With our best regards, PANAMASIA WEST COAST, INC.

Lynn Walker Sales Manager Auto Parts

DIRECTIONAL LAMP - 12 VOLT

APPLICATION:

THIS IS AN ADD-ON ACCESSORY FOR PASSENGER CARS.

INSTALLATION:

IT IS INSTALLED ON TOP OF THE FRONT FENDERS ABOVE THE HEAD LAMP. APPLICATION IS STICK-ON. THE WIRE CAN BE RUN INTO THE ENGINE COMPARTMENT AS IN THE ILLUSTRATION, OR THE INSTALLER MAY DRILL A HOLE IN THE FENDER DIRECTLY UNDER THE LAMP AND RUN THE WIRE THR OUGH IT.

VISABILITY:

THE LENSE IS VISIBLE FROM ALL DIRECTIONS. THE LENSE AREA IS THE AREA HIGHLIGHTED IN YELLOW IN DIAGRAM 1. ALSO, PLEASE ADVISE US OF THE LEGALITY OF THE SAME LAMP IF IT WERE VISIBLE ONLY TO THE REAR (VISIBLE TO THE DRIVER).

MATERIAL: THE BASE IS OF FLEXIBLE PLASTIC. THE HOUSING AROUND THE LENSE IS OF METAL. THE LENSE IS PLASTIC. LENSE COLOR IS GREEN, BUT COULD BE ANY COLOR THAT IS LEGAL FOR HIGHWAY USE.

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