Interpretation ID: nht75-2.15

DATE: 04/21/75

FROM: AUTHOR UNAVAILABLE; J. C. Schultz; NHTSA

TO: Dominion Auto Accessories Limited

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of March 20, 1975, inquiring as to the permissibility of selling your "Panamirror" in the United States as aftermarket equipment.

Motor Vehicle Safety Standard No. 111, Rearview Mirror, provides minimum performance requirements for rearview mirrors on passenger cars and multipurpose passenger vehicles. According to the standard, the inside rearview mirror must furnish the driver with a specified field of view to the rear of substantially unit magnification. Any vehicle manufactured for sale, sold, or introduced into interstate commerce must be equipped with an inside rearview mirror that meets the designated level of performance. It appears that the "Panamirror" would not satisfy the requirements of the provision, because it is convex in structure and therefore would not provide a view of substantially unit magnification.

If the mirror were installed on a vehicle as aftermarket equipment (after the vehicle's first purchase for purposes other than resale) in such a way as to render inoperative the inside rearview mirror, section 108(a) (2) (A) of the National Traffic and Motor Vehicle Safety Act (Pub. L. 89-563) as amended (Pub. L. 93-492) would apply where the installation was accomplished by a manufacturer, distributor, dealer, or motor vehicle repair business. The section prohibits the named parties from knowingly rendering inoperative a system installed in compliance with an applicable motor vehicle safety standard.