Interpretation ID: aiam4245
16722 23rd Ave. S.E.
Bothell
WA 98012;
Dear Mr. Jensen: Your letter of September 10, 1986, has been forwarded to this offic for reply. You have devised a way 'to inscribe lettering on the inside of car & truck taillights so that when the brakes are applied the lettering is seen.' You asked if there are any laws that apply to this concept.; Because you wish to produce this concept we shall consider it as bot original equipment installed by the vehicle manufacturer, and as equipment available in the aftermarket, for purchase by a vehicle owner. The Federal regulation governing vehicle lighting equipment is Federal Motor Vehicle Safety Standard No. 108. It requires a manufacturer to produce vehicles with certain specified lighting devices meeting specific requirements. Further, under it, additional lighting devices and other motor vehicle equipment are permissible provided they do not impair the effectiveness of the lighting equipment required by the standard. The requirements for stop lamps (you called them 'tail lights', but taillamps are the rear lights that are on when the headlamps are on, and are not brake activated) are those of SAE Standard J586c, August 1970. It specifies photometric requirements to be met at specific test points, and a minimum effective projected luminous lens area for lamps.; With respect to compliance with the stop lamp requirements of Standar No. 108, the lettering must not prevent the lamp from meeting photometrics at the applicable test points, or from complying with the minimum area requirements. As to whether the concept would nevertheless impair the effectiveness of the stop lamps, this is a decision to be made by the vehicle manufacturer, though it is subject to review by this agency. Anything that distracts the observer of a stop lamp from instantaneously perceiving its message could be considered an impairment.; As an aftermarket device, it is not subject to Standard No. 108, bu only to the restriction imposed by the National Traffic and Motor Vehicle Safety Act that manufacturers, dealers, and motor vehicle repair businesses must not render inoperative in whole or in part devices such as stop lamps that are installed as original safety equipment. If your device created a noncompliance in the stop lamp, or impaired the effectiveness of it, we would consider this the equivalent of rendering the stop lamp partially inoperative.; Your concept would also be subject to the laws of any State in which device embodying it is sold or used. We are unable to advise you as to these laws, but you must consider them as well.; I hope that this answers your question. Sincerely, Erika Z. Jones, Chief Counsel