Interpretation ID: aiam3867
Sierra Product
Inc.
1113 Greenville Road
Livermore
CA 94550;
Dear Mr. Moore: This is in reply to your letter of November 26, 1984, asking whether i is permissible under Motor Vehicle Safety Standard No. 108 to combine a turn signal lamp with a center high mounted stop lamp that is intended for the aftermarket as a retrofit.; As you have noted, the recent amendments to Standard No. 108 cover th center high mounted stop lamp only as an item of original equipment and do not purport to regulate the item as an aftermarket device. This means that the prohibition of paragraph S4.1.1 against combining the center high mounted stop lamp with any other lamp does not apply. The legality of such a combination, indeed, the legality of the auxiliary stop lamp itself, is determinable under the laws of any State in which a vehicle so equipped is registered and/or operated.; The sole federal restriction on use of aftermarket devices does no appear in Standard No. 108, but in the National Traffic and Motor Vehicle Safety Act. Section 108(a)(2)(A) in essence forbids a manufacturer, distributor, dealer, or motor vehicle repair business from rendering inoperative in whole or in part lighting equipment installed in accordance with Standard No. 108. The combination turn signal/center high mounted lamp would not appear to have this effect.; I hope that this is responsive to your request. Sincerely, Frank Berndt, Chief Counsel