Interpretation ID: nht93-3.41

DATE: May 10, 1993

FROM: John Womack -- Acting Chief Counsel, U.S. Department of Transportation, NHTSA

TO: Margret Schmock von Ohr -- Robert Bosch GmbH, BOSCH Reutlingen

TITLE: None

ATTACHMT: Attached to rapifax/fax dated 3-5-93 from Margaret Schmock von Ohr to Tylor Vinson

TEXT: This responds to your FAX of May 3, 1993, to Taylor Vinson of this Office, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it relates to reflex reflectors.

Under Standard No. 108, the front side marker reflex reflector must be amber in color. You have asked whether it is permissible to have an amber painted reflex reflector lens, and the conditions under which it is permissible to have it painted.

Standard No. 108 incorporates by reference SAE Standard J594f REFLEX REFLECTORS, January 1977. Neither J594f nor the text of Standard No. 108 itself prohibit an amber painted reflex reflector lens. As with any item of motor vehicle equipment subject to Standard No. 108, its manufacturer must ensure that the product as manufactured has been designed to comply with applicable Federal requirements. Thus, the amber painted reflex reflector lens is permissible provided that the front reflex reflector assembly meets all requirements of Standard No. 108 including the referenced SAE J594f.