Interpretation ID: aiam4607
General Manager Technical Information Dept. Koito Mfg. Co.
Ltd. Shizuoka Works 500
Kitawaki Shimizu-shi
Shizuoka-ken Japan;
Dear Mr. Iwase: This is in reply to your letter of March 20, l989 asking for an interpretation of Motor Vehicle Safety Standard No. l08 as it applies to the location of the license plate lamp on motor vehicles. You noted the language in Tables II and IV of Standard No. l08 specifying that the lamp is to be located 'at rear license plate, to illuminate the plate from the top or sides,' for vehicles other than motorcycles. The requirement for motorcycles (Table IV) is simply that it be located 'at rear license plate.' You have asked for confirmation that, except on motorcycles, the license plate lamp shall not illuminate the plate from the bottom. Your interpretation is correct. The rationale for the requirement is that in a location other than at the bottom, the license plate lamp is less likely to be obstructed by snow or mud. I hope that this answers your question. Sincerely, Stephen P. Wood Acting Chief Counsel /;