Interpretation ID: 19499.ztv
Mr. James Cowell
General Manager
Topline Products
No. 1 Topline Plaza
4651 State Street
Montclair, CA 91763
Dear Mr. Cowell:
This is in reply to your letter of January 27, 1999, "requesting approval to use a product in regard to Federal motor vehicle safety standard 108 lighting rules." You understand that "some types of auxiliary lighting are allowed as long as they do not interfere with the standard equipped vehicle lighting such as head lamps, turn signals, and other factory lighting."
Topline wishes to market a "Chevrolet light truck bowtie emblem that glows in the dark," using "an electro luminescent panel." You have enclosed two photos showing the device mounted on a truck at night when the truck's front lamps are lit.
Let me begin by saying that we have no authority to approve or disapprove items of lighting equipment. We do provide manufacturers of auxiliary lighting equipment with opinions regarding the relationship of their devices to Federal law. Your understanding of the relationship of your device as original equipment to Federal Motor Vehicle Safety Standard No. 108 is correct; the luminescent bowtie is permitted if it does not impair the effectiveness of lighting equipment that Standard No. 108 requires. After studying your photos, it does not appear to us that the light level of the luminescent bowtie is high enough to impair the effectiveness of the other front lighting equipment on a truck. Because the bowtie does not create a noncompliance with Standard No. 108, it is not a violation of Federal law for it to be installed as an aftermarket device.
Whether it is legal to use the luminescent bowtie emblem depends on state and local laws. We note that the color of the device is blue. Some states restrict the use of blue lighting to emergency vehicles. Whether a state with such a law would apply it to use
of this small device we cannot say, as we are not conversant with laws of the individual states.
You should contact the individual states in which you intend to sell your products. You may also wish to contact:
American Association of Motor Vehicle Administrators
4301 Wilson Blvd., Suite 400
Arlington, VA 22203
V: 703 522 4200
F: 703 522 1553
Faxback: 888 226 8237
This organization promotes cooperation among the states with motor vehicle safety, administrative matters, and other issues of importance to motor vehicle use.
You may also wish to contact:
Automotive Manufacturers Equipment Compliance Agency, Inc.
1101 15th St., N.W. Suite 607
Washington, DC 20005
V: 202 898 0145
F: 202 898 0148
This organization is a centralized voluntary agency that notifies government, industry and the public about items of motor vehicle safety equipment that have been tested by accredited laboratories and found to be in compliance with applicable United States industry, state and federal standards.
If you have any questions you may call Taylor Vinson of this Office (202-366-5263).
Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.3/3/99