Interpretation ID: aiam3821
Pleasant Valley Corporate Center
Suite 800
2024 Arkansas Valley Drive
Little Rock
AR 72212- 4237;
Dear Mr. Ablondi: This responds to your March 16, 1984 letter regarding the applicabilit of Federal Motor Vehicle Safety Standard (FMVSS) 111 to an aftermarket rearview mirror which one of your clients proposes to market. This mirror would be attached to the original equipment inside mirror stalk in such a way that the view through the OEM mirror is unimpaired. Your client's mirror would permit the driver to view children in the rear seat of the vehicle.; FMVSS 111 (see 49 C.F.R. 571.111, copy enclosed) is directly applicabl to new motor vehicles only. However, that standard may apply indirectly to aftermarket mirrors through the operation of 15 U.S.C. 1397(a)(2)(A). The latter provision prohibits any motor vehicle manufacturer, distributor, dealer, or repair business from rendering inoperative any 'device or element of design installed on or in a motor vehicle...in compliance with an applicable Federal motor vehicle safety standard...' Thus, the installation of a replacement or even a supplemental rearview mirror in a motor vehicle could be unlawful if that installation resulted in a mirror system which did not comply with the requirements of FMVSS 111.; Based on your description of your client's mirror, it does not appea that the aftermarket installation of that mirror would be prohibited under 15 U.S.C. 1397(a)(2)(A), since the operation of the OEM mirror system is unaffected by the addition of the aftermarket mirror.; If you have any further questions on this matter, please contact us. Sincerely, Frank Berndt, Chief Counsel