Interpretation ID: nht76-2.22

DATE: 04/30/76

FROM: JOHN WOMACK FOR FRANK BERNDT -- NHTSA

TO: Allegrette; Newitt; Witcoff & McAndrews

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of February 12, 1976. Currently, 49 CFR Part 566, Manufacturer Identification, does not require, or provide for, a manufacturer code number. The use of a code number has been proposed, but not adopted. If the use of a code number becomes mandatory, notice will appear in the Federal Register and a sufficient amount of time allowed for your client to comply.

The information you submitted in your letter is sufficient to satisfy the requirements of Part 566. Inasmuch as Tsuyama Mfg. Co., Ltd., is a foreign corporation, it will be necessary for them to designate an agent pursuant to 49 CFR 551.45.

Your understanding with respect to certification of lenses is correct. Section S4.7.2 of Standard No. 108, Lamps, Reflective Devices, and Associated Equipment (49 CFR 571.108), permits replacement equipment to be marked with the symbol DOT as a certification that it conforms to all applicable Federal motor vehicle safety standards, and there is no need to submit lenses to us for approval.

ALLEGRETTI, NEWITT, WITCOFF & MCANDREWS

February 12, 1976

Administrator, National Highway Traffic Safety Administration

I am writing in behalf of Tsuyama Mfg. Co., Ltd. of Osaka, Japan re Title 49 CRF, Part 566 and 567. Tsuyama Mfg. Co., Ltd, is a Japanese corporation and has its principal place of business at 53, 3-Chome, Kuwazu-cho, Higashi Sumiyoshi-ku, Osaka, Japan. Our client manufacturers reflectors, lenses and lamps for motor vehicles. The foregoing should enable you to provide a code number for our client under 49 CRF @ 566.5. If anything more is required, please advise.

Tsuyama Mfg. Co., Ltd. intends to sell a replacement lens for a combination rear lamp that meets all applicable SAE standards. I understand it would be proper for my client to emboss, mark or label its lenses with the symbol DOT after the lenses have been tested for compliance with the applicable standards and that there is no need to submit specimens of the lenses or other products to the Administrator for prior approval. Please confirm that my understanding is correct.

Seymour Rothstein