Interpretation ID: nht89-1.45

TYPE: INTERPRETATION-NHTSA

DATE: 03/20/89

FROM: M. IWASE -- TECHNICAL ADMINISTRATION DEPT. KOITO MFG. CO., LTD.

TO: ERIKA Z. JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 06/19/89 FROM ERIKA Z. JONES -- NHTSA TO M. IWASE; REDBOOK A33; STANDARD 108

TEXT: Dear Ms. Jones,

Koito would like to confirm the following prescription of license plate lamp in Table II and IV of FMVSS No. 108.

TABLE II - LOCATION OF REQUIRED EQUIPMENT Location on Height above Item Multipurpose passenger Trailers road surface vehicles, trucks, and busses measuredLicense At rear license plate, to At rear license plate, to No plate illuminate the plate from the illuminate the plate from requirement lamp top or sides. the top or sides. TABLE IV - LOCATION OF REQUIRED EQUIPMENT Location on Height above Item Passenger cars, multipurpose Motorcycles road surface passenger vehicles, measuredLicense At rear license plate, to At rear license plate No plate illuminate the plate from the requirementlamp top or sides.

We interpret that the license plate lamp is not permitted to illuminate the plate from the bottom (except Motorcycle).

We would greatly appreciate if you would kindly and promptly give us your confirmation as to whether the illumination from the bottom be permissible.

Sincerely yours,