Interpretation ID: 11275
International Regulatory Affairs ManagerValeo
34, rue Saint-AndrJ
93012 Bobigny Cedex
France
Dear M. Dorleans:
This responds to your letter of September 29, 1995, with respect to the use of light-emitting diodes (LEDs) to fulfill the lighting requirements of Standard No. 108.
You have enclosed a design for a lamp incorporating tail, stop, and rear turn signal functions, the illumination for which will be provided by red LEDs. At night, the LEDs will provide sufficient illumination to meet taillamp photometrics, with increased illumination when the brake pedal is applied, "so that the sum of the photometrics of the stoplamp and the tail lamp is fulfilled." When the turn signal is activated, "all the diodes are energized at full intensity during the on-period of the turn signal [and] [t]he sum of the photometrics of the rear turn signal lamp and the tail lamp is then fulfilled . . . ." You ask for "confirmation that this new lighting combination is correct."
We consider this lamp, as you have more fully described it in your letter, to be an acceptable design for meeting the requirements of Standard No. 108.
If you have any questions, you may refer them to Taylor Vinson of this Office (phone: 202-366-5263).
Sincerely,
Samuel J. Dubbin Chief Counsel
ref:108 d:11/9/95