Interpretation ID: 18756.ztv

Mr. Hardy Huber
President
DiBlasi of America, Inc.
2633 Lantana Road, Suite 19
Lantana, FL 33462

Dear Mr. Huber

This is in reply to your letter of September 9, 1998, to the agency asking "whether mopeds are required to have a speedometer, and, if the answer is yes, does the speedometer [have] to be lighted."

The agency has not adopted the term "moped" in regulating two-wheeled motor vehicles. However, a motorcycle with 5 horsepower or less is called a "motor driven cycle," and we believe that this definition encompasses mopeds. The many Federal motor vehicle safety standards that apply to "motorcycles" will also apply to "motor driven cycles" unless an exception is specifically made within the text of the standard.

However, this distinction is not important in terms of your questions. Federal Motor Vehicle Safety Standard No. 123, Motorcycle Controls and Displays, does not require motorcycles of any sort to be equipped with a speedometer. However, if a manufacturer chooses to provide a speedometer, Standard No. 123 requires that it be illuminated whenever the headlamp is activated. It also requires that the speedometer be marked "m.p.h," increasing in a clockwise direction. The standard further requires that major graduations and numerals to appear at 10 mph intervals and minor graduations at 5 mph intervals.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:123
d/11/20/98