Interpretation ID: 7400
Vice President
Pioneer Electronic Services, Inc.
P.O. Box 1760
Long Beach, CA 90801-1760
Dear Sir:
This responds to your letter of June 5, 1992, with reference to your plan to sell a new car speaker in the U.S. It will be installed "in the rear deck" with the "Pioneer brand name to be printed on the rear side of the speaker cabinet." The brand name will be lit "with blue color at night" and "there are 8 lamps for each left and right speaker." The brightness of the lamp is "just 1/40 of the high mount stop lamp." You believe that the "illuminated speaker will not impair the effectiveness of the existing lighting equipment installed into the car."
We understand that the speaker will be sold as aftermarket equipment, not as original equipment. Installation of the speaker by a manufacturer, distributor, dealer, or motor vehicle repair business is permissible under the National Traffic and Motor Vehicle Safety Act as long as it does not render inoperative, in whole or in part, any of the rear view mirror or lighting equipment that is required by Federal Motor Vehicle Safety Standard No. 108. The drawing you enclosed, and the description of the speaker, are insufficient for us to provide you a definitive interpretation. For instance, it is not possible to tell whether the light is oriented to the rear, so that it will be seen through the rear window, adjacent to the center highmounted stop lamp, or whether it is oriented to the front, so that it will reflect in the rear view mirror. In either location, it may have the potential to affect negatively the safety performance of rear view mirrors or the rear center stop lamp. Taylor Vinson of this Office telephoned your company on June 22, suggesting that it furnish a clearer drawing and a better description. As of the date of this response, we have heard nothing further from you.
Further, there are state laws that prohibit illumination in vehicle interiors under certain conditions. We are unable to advise you of these laws. The American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203, may be able to provide you with an interpretation.
Sincerely,
Paul Jackson Rice Chief Counsel
ref:VSA d:7/31/92