Interpretation ID: 3138o
156 Holland Road
Ormond Beach, FL 32074
Dear Mr. Crockenberg:
This is in response to your letter of February 26, 1988, concerning antiglare plexiglass shields. I regret the delay in our response. You asked whether Standard No. 103, Windshield Defrosting and Defogging Systems, Standard No. 111, Rearview Mirrors, or any other Federal Motor Vehicle Safety Standard applies to your product, a 4" x 6" x 1/8" parallelogram with rounded corners made of transparent bronze plexiglass with an attached 1/2" diameter suction cup. You noted that this device, which adheres to the interior of automobile windows, deflects obstructive sunglare where conventional sun visors cannot be placed. You also asked what other agency's regulations you should be aware of before you begin to manufacture and market this device, if none of our standards apply.
You are correct in assuming that Standard No. 103 and Standard No. 111 do not apply to your product. The only Federal Motor Vehicle Safety Standard that is relevant to your product is Standard No. 205, Glazing Materials. S2 states that one purpose of this standard is to "ensure a necessary degree of transparency in motor vehicle windows for driver visibility." S1 and S3 note that Standard No. 205 applies to glazing materials in both motor vehicles and motor vehicle equipment. I am enclosing an agency "fact sheet," which concerns the tinting of motor vehicles and motor vehicle equipment. I also am enclosing two previous NHTSA interpretation letters, which concern products similar to your antiglare shield. These letters to Susan House on December 20, 1985 and to Jeffrey Richard on April 16, 1985 explain the effect of Standard No. 205 on a manufacturer of such a product.
In response to your second question, I have enclosed a copy of an information sheet for new manufacturers of motor vehicles and motor vehicle equipment. This identifies other agencies whose regulations might be applicable to a new manufacturer's products.
I hope this information is helpful.
Sincerely,
Erika Z. Jones Chief Counsel
Enclosures
/ref:205 d:ll/l/88