Interpretation ID: nht69-1.50

DATE: 04/29/69

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: Hueck and Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 22, 1969, requesting a clarification of the location requirements for license plate lamps as specified in Federal Motor Vehicle Safety Standard No. 108.

As you indicated, Standard No. 108 currently references SAE Standard J587B and also permits the location of license plate lamps at the top, side or bottom of the license plate. The latest revision of SAE Standard J587 (J587c) is no way changes the location provision of Standard No. 108. Therefore, a license plate lamp assembly may be tested according to SAE Standard J587b and Standard No. 108 when the license plate is illuminated from the bottom.

Section 103(d) of the National Traffic and Motor Vehicle Safety Act of 1966 states: "Whenever a Federal motor vehicle safety standard established under this title is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard." Therefore, any State regulations on the location of license plate lamps should be identical to the requirements of Standard No. 108 on and after the effective date of the standard.