Interpretation ID: aiam4328
Manager
Automotive Lighting
Engineering Control Department
Stanley Electric Co.
Ltd.
2-9-13
Nakameguro
Meguro-ku
Tokyo 153
Japan;
Dear Mr. Chikada: This is in reply to your letter of March 4, 1987, with reference t aiming adjustment of fog lamps. We understand that Stanley is developing a fog lamp and replaceable bulb headlamp with a common lens and housing. Since the portion of the housing also functions as a reflector, the fog lamp moves simultaneously with the headlamp in aiming adjustment. In your view, it will not impair the effectiveness of the headlamp, and you ask for confirmation that the lamp 'is acceptable in the U.S.A.; Federal Motor Vehicle Safety Standard No. 108 contains no requirement for a fog lamp, and would prohibit it only if it impaired the effectiveness of any other lamp mounted on the front of a vehicle that is required by the standard. Assuming that the fog lamp does not impair the effectiveness of the headlamp, its installation would not crate a noncompliance with Standard No. 108. However, in the absence of a Federal standard on fog lamps, the individual States may establish their own requirement for fog lamps. We are unable to advise you whether this design would be acceptable in each of the 50 States, and other jurisdictions in which the Federal standards must be met, we can only advise you that it does not appear prohibited by Federal law.; The American Association of Motor Vehicle Administrators (AAMVA). 120 Connecticut Avenue, N.W., Washington, D.C., 20036 may be able to advise you as to state laws relevant to your design.; Sincerely, Erika Z. Jones, Chief Counsel