Interpretation ID: aiam4904
WI 53711;
"Dear Mr. Covelli: This responds to your recent undated letter t Taylor Vinson of this Office with respect to whether Federal law allows the use of decals on center highmounted stop lamps. You report that Wisconsin has no law governing the use of a decal on the brake light. THe subject is a complicated one under Federal law, but I shall try to explain it as simply as possible. There is no restriction under Federal law on the application of a decal to the center stop lamp, if the decal is placed there by the vehicle owner. Center stop lamps were not required on passenger cars manufactured before September 1, l985, and there are no Federal restrictions upon application of decals to lamps on pre-l986 model cars that may have been retrofitted with them. With respect to application of the decal on the center lamp of a passenger car manufactured on or after September 1, l985, Federal law prohibits the application a decal by a manufacturer, distributor, dealer, or repair shop, either before or after its sale to the first owner, if the application of the decal creates a noncompliance with the Federal motor vehicle safety standard on lighting. Conversely, such application is permitted if the lamp remains in compliance with all applicable Federal requirements with the decal installed. For example, the Federal standard calls for a minimum 'effective projected luminous area' of 4 l/2 square inches. Application of a decal to a lamp meeting the minimum area requirement would reduce the effective projected luminous area below 4 1/2 square inches, creating a noncompliance. On the other hand, if that area were large enough, and more than 4 1/2 square inches of it remained after the application of a decal, application of the decal would not create a noncompliance with the luminous area specification. The standard also calls for measurement of photometric performance at certain specified test points on the lamp. Obviously, the lamp must continue to provide the minimum photometric performance specified by the standard for those test points with the decal applied. Thus, whether application of a decal by a manufacturer, distributor, dealer, or repair shop creates a noncompliance is dependent upon the size of the lamp and the size, lettering, and transparency of the decal. Sincerely, Paul Jackson Rice Chief Counsel";