Interpretation ID: nht95-4.22

TYPE: INTERPRETATION-NHTSA

DATE: September 18, 1995

FROM: Yoshiaki MATSUI -- Manager, Automotive Equipment, Stanley Electric Co.

TO: Chief Counsel, NHTSA

TITLE: Accessory Lamp with LEDs

ATTACHMT: Attached to 11/9/95 letter from Samuel J. Dubbin to Yoskiaki Matsui (Std. 108)

TEXT: We, a Japanese manufacturer of automotive lighting devices, are now developing a new type of combination rear lamp that contains red LEDs as accessory lamps. (Please refer to the attached drawing). Would you please advise us about the categorization of this kind of LED accessory lamps.

The operating condition of the LED accessory lamps are as follows,

a) Construction of the combination rear lamp

Tail & stop lamp and turn signal lamp vertically arranged. Red LEDs are disposed along the outer edge of the combination lamp to be used as accessory lamps.

Light source Colour of Colour of the lens light emitted Tail & stop Incandescent bulb Red Red Rear turn Incandescent bulb Amber Amber signal

b) Operating condition for the accessory lamps

When the tail lamp is switched on, the Accessory Lamp A of red LEDs, which is adjacent to the tail lamp, and the Accessory Lamp B of red LEDs, which is adjacent to the rear turn signal lamp, are lit.

Question 1: Red LEDs adjacent to the tail lamp (Accessory Lamp A)

The tail lamp is designed to comply with FMVSS No. 108 using incandescent bulb only, therefore red LEDs need not to be lit for the purpose of the regulatory requirements. Moreover, when the tail lamp and the red LEDs (Accessory Lamp A) are lit together, the intensity of the light emitted from them does not exceed the maximum intensity specified for one lighted section tail lamp.

In such a condition, we believe the red LEDs (Accessory Lamp a) could be regarded as an accessory.

As for the safety, red LEDs (Accessory Lamp A) will contribute to safety by improving the comspicuity of the vehicle, when lit with the tail lamp.

If our interpretation is not acceptable, please inform us of the conditions required in order to regard the red LEDs portion (Accessory Lamp A) as an accessory.

Question 2: Red LEDs adjacent to the rear turn signal lamp (Accessory Lamp B)

Q2-1: As for the red LEDs adjacent to the rear turn signal lamp (Accessory Lamp B), the LEDs emit a red colour light through the amber lens. The lighted section of the red section of the turn signal lamp by a parting rib prepared in the housing, so that the red light from red LEDs will not be emitted through the lens area of the lighted section of the rear turn signal lamp. Therefore, we believe the light from the red LEDs (Accessory Lamp B) will not adversely affect the rear turn signal function even if the red LEDs (Accessory Lamp B) continues to operate when the rear turn signal lamp is operated. Please advise us if our interpretation is acceptable.

Q2-2: If our interpretation described in the above A2-1 is not acceptable, are the red LEDs (Accessory Lamp B) regarded as an accessory provided that the red LEDs (Accessory Lamp B) are turned off during the rear turn signal operation?

Following table shows the lighting condition of Accessory Lamps and our interpretation.

Tail lamp ON Operating Accessory Lamp A ON condition Accessory Lamp B ON OFF Rear turn signal lamp ON OFF ON OFF STANLEY's question Q2-1 Q2-2 Question STANLEY's interpretation OK OK OK OK NHTSA's answer

Your answer will be highly appreciated.

(Drawing omitted.)