Interpretation ID: aiam2350
Pacet International
1192 First Avenue
New York
NY 10021;
Dear Mr. Mole:#This is in response to your June 15, 1976, questio whether Arcoflex windshield wiper blades must be certified as being in compliance with Federal motor vehicle safety standards before they may be sold as aftermarket equipment through vehicle distributors' dealer parts programs.#Standard No. 104, *Windshield Wiping and Washing Systems*, requires vehicles to be equipped with a power-driven windshield wiping system that meets specified performance requirements. It is up to vehicle manufacturers to certify that each vehicle they produce conforms to the requirements of Standard No. 104, in accordance with the certification procedures specified in 49 CFR Part 567.#Standard No. 104 is not an equipment standard, however, and is not applicable to wiper blades sold in the aftermarket. Therefore, there is no requirement that Arcoflex windshield wiper blades be certified, so long as they are not installed on vehicles as part of the wiping system prior to the first sale of the vehicle.#Sincerely, Frank A. Berndt, Acting Chief Counsel;