Interpretation ID: nht72-2.26

DATE: 01/11/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Westinghouse Electric Corporation

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of December 22, 1971 to Lawrence R. Schueider you ask for a clarification of the relationship between 49 CFR Part 566 "Manufacturer Identification, and 49 CFR @ 571.108, Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment. Specifically you ask whether identifying information is required for miniature bulbs.

Standard No. 108 establishes performance requirements for items of motor vehicle lighting equipment, and incorporates by reference certain SAE standards that specify requirements lamps must meet in laboratory tests when assembled. The SAE standard that applies to bulbs: J573d, Lamp Bulbs and Sealed Units, is not incorporated by reference, and Standard No. 108 contains no requirements for the output of bulbs furnished with a lamp assembly. When a lamp is tested for conformity, the production bulb is removed and a calibrated bulb substituted, in accordance with Paragraph 0 of SAE Standard J575d, Tests for Motor Vehicle Lighting Devices and Components; the test bulb is to be "representative of Standard bulbs in regular production" and must be "selected for accuracy in accordance with specifications listed in . . . SAE J573." In summary, Standard No. 108 does not specify performance requirements for lamp bulbs, and production bulbs are not used in lamp testing. Therefore, Standard No. 108 does not apply to bulbs and bulb manufactures are not required to certify conformance to Federal standards, or to submit information pursuant to the Manufacturer Identification regulations.