Interpretation ID: 2401y
President
Network USA Inc.
136 Walker St., SW
Atlanta, GA . 30313-1326
Dear Mr. Maday:
This is in reply to your letter with respect to the automatic light switching device whose potential for the U.S. market you are assessing. The device automatically activates the headlamps at a pre-determined (but adjustable) level of darkness. There is a manual override for the operator. I regret the delay in responding.
You have asked two questions:
"l. What legislation is in force or pending regarding the mandatory utilization of such daytime running lights for vehicles?"
None. The agency once proposed that motor vehicles be equipped with daytime running lamps as an option, but it terminated rulemaking on this subject without taking action.
"2. What regulations, standards, forms, etc. have to be submitted to you or the appropriate agency to ensure that the product meets any U.S. specifications or standards prior to importation.
None. There are no Federal motor vehicle safety standards that apply to this item of motor vehicle equipment. However, if you intend it to be installed as an item of original equipment, it must not create a noncompliance with Motor Vehicle Safety Standard No. l08 Lamps, Reflective Devices, and Associated Equipment, or result in an impairment of the effectiveness of the lighting equipment that the standard requires. For example, the standard requires the taillamps to be activated when the headlamps are activated. Therefore, when your device activates the headlamps, the taillamps must also be activated. Though expressed in somewhat different terms, the acceptability of your device in the aftermarket is governed by a similar consideration: it may not be installed by a motor vehicle manufacturer, distributor, dealer or repair business if the installation would render inoperative any element of design or device installed in accordance with Standard No. l08. The device would remain subject to the laws of any State in which it is sold or operated. We are unable to advise you as to its acceptability under State laws, and recommend that you consult the American Association of Motor Vehicle Administrators (AAMVA), 4600 Wilson Boulevard, Arlington, Va. 22203.
Sincerely,
Stephen P. Wood Acting Chief Counsel
ref:l08 d:4/8/90