Interpretation ID: aiam4183
323 Jefferson Drive
Guilford
CT 06437;
Dear Mr. Silidker: This is in reply to your letter of July 15, 1986, to Mr. Vinson of m staff, bringing to our attention the lack of a center high-mounted stop lamp on your 1986 Nissan Stanza wagon, and asking us to look into this matter. You have enclosed a letter from Nissan informing you that your wagon has 4-wheel drive and thus is not certified as a 'passenger vehicle' required to have the light. However, you believe that manufacturers of other 4-wheel drive vehicles are providing the new lamp.; Federal Motor Vehicle Safety Standard No. 108 requires the new lamp a original equipment on all 'passenger cars' manufactured on and after September 1, 1985. It is not required on other types of motor vehicles such as 'multipurpose passenger vehicles'. This latter category is defined for purposes of the Federal motor vehicle safety standards as a vehicle constructed on a truck chassis, or with special features for occasional off- road operation. The principal feature for such operation is 4- wheel drive. If a 4-wheel drive vehicle is built on a passenger car chassis, its manufacturer may treat it as either a 'passenger car' or 'multipurpose passenger vehicle' for purposes of compliance with the safety standards, and for purposes of certification to those requirements. We believe that the certification plate permanently attached to the door post of your Stanza identifies it as a 'multipurpose passenger vehicle' and that Nissan is therefore not required to provide the center mounted stop lamp.; As for the reason that the lamp is installed on other 4-wheel driv vehicles, it may be that they are certified as passenger cars, or that their manufacturers have voluntarily chosen to equip them with the new lamp.; Thank you for your interest in safety. Sincerely, Erika Z. Jones, Chief Counsel