Interpretation ID: 77-1.44

TYPE: INTERPRETATION-NHTSA

DATE: 03/10/77

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Stanley Electric Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 14, 1977, concerning the symbol "DOT" as a certification of compliance to FMVSS No. 108.

The symbol "DOT" is permitted by the Standard to be placed on the item of equipment in lieu of the certification requirements of Section 114 of the "National Traffic and Motor Vehicle Safety Act of 1966," which states, in part ". . . In the case of an item of motor vehicle equipment such certification may be in the form of a label or tag on such item or on the outside of a container in which such item is delivered . . ."

"DOT" on the individual container does not meet the certification requirements. The label or tag must state that the item "conforms to all applicable Federal motor vehicle safety standards."

Sincerely,

ATTACH.

STANLEY ELECTRONIC CO. LTD.

February 14, 1977

E. T. Driver -- Director, Office of Crash Avoidance Motor, Vehicle Programs,

U. S. Department of Transportation, National Highway Traffic Safety Administration

Dear Mr. Driver,

Our lighting equipment to which F.M.V.S.S. 108 is applicable are now being directly labeled with symbol "DOT" as a certification of compliance to that standard.

We are now considering to label this symbol "DOT" on an individual container in which each item of equipment is packaged, instead of labelling it on the item itself.

Please let us have your comment on whether the labelling with symbol "DOT" container is acceptable or not.

Thanking you in advance for your cooperation,

Yours faithfully, H. Miyazawa -- Director, Automotive Lighting, Engineering Dept.