Interpretation ID: aiam4397
President
Stardor International Pty Ltd.
Suite A803 The Towers
1111 Crandon Blvd.
Key Biscayne
FL 33149;
Dear Mr. McIntosh: This is in reply to your recent undated letter to Taylor Vinson of thi office, requesting 'approval' of your Rear Ender stop lamp. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 *et seq*.) does not permit this agency to assure a manufacturer that its lighting equipment complies with all applicable requirements or to 'approve' any lighting equipment. Instead, section 114 of the Safety Act requires the manufacturer itself to certify that its lighting equipment complies with all applicable safety standards. Because of this statutory requirement, NHTSA cannot 'approve' your stop lamp or offer assurances that the stop lamp complies with all applicable safety standards. We can, however, state whether your lighting equipment appears to comply with the safety standards, based solely on the information set forth in your letter.; Your product is intended to be used as a center highmounted stop lamp One of the claims for the lamp made in the product literature that you enclosed is that 'Unlike many other rear brake lens' this one 'features a wider vision reflector....'; Paragraph S4.4 of Federal Motor Vehicle Safety Standard No. 108 *Lamps Reflective Devices, and Associated Equipment* prohibits combining the center highmounted stop lamp with any other lamp or reflective device. Because your lamp appears to incorporate a reflector with the lens it would not be acceptable as original equipment for passenger cars, or as replacement equipment for cars manufactured with a center highmounted lamp (generally those produced since September 1, 1985). You may be interested to know that we have expressed views on designs similar to concept to yours, but that did not appear to combine the lamp with another lamp or reflective device. I have enclosed an example of such an opinion letter.; There are no Federal restrictions applicable to use of your product o vehicles other than passenger cars, or on passenger cars manufactured before September 1, 1985, that were not equipped with a center highmounted stop lamp as original equipment. The acceptability of the device for these vehicles is determined by the laws of the States in which these vehicles would be registered and operated.; I hope that this answers your questions. Sincerely, Erika Z. Jones, Chief Counsel