Interpretation ID: aiam0558
Esq.
Counsel
Lamp Division
General Electric Company
Nela Park
Cleveland
OH 44112;
Dear Mr. Burnor: This is in reply to your letter of December 21 to Mr. Vinson of thi office asking for confirmation of your understanding that manufacturers of bulbs for 'automotive replacement lamps and devices' are not required to certify compliance with Federal Motor Vehicle Safety Standard No. 108.; Standard No. 108 establishes performance requirements for items o motor vehicle lighting equipment, and incorporates by reference certain SAE standards that specify requirements lamps must meet in laboratory tests when assembled. The SAE standard that applies to bulbs, J573d, *Lamp Bulbs and Sealed Units*, is not incorporated by reference, and Standard No. 108 contains no requirements for the output of bulbs furnished with a lamp assembly. When a lamp is tested for conformity, the production bulb is removed and a calibrated bulb substituted, in accordance with Paragraph C of SAE Standard J575d, Tests for Motor Vehicle Lighting Devices and Components, the test bulb is to be 'representative of standard bulbs in regular production' and must be 'selected for accuracy in accordance with specifications listed in . . . SAE J573.'; In summary, Standard No. 108 does not specify performance requirement for lamp bulbs, and production bulbs are not used in lamp testing. Therefore, Standard No. 108 does not apply to bulbs and bulb manufacturers are not required to certify conformance to Federal standards, or to submit information pursuant to the *Manufacturer Identification* regulations.; Sincerely, Richard B. Dyson, Assistant Chief Counsel