Interpretation ID: aiam3925
JBR Manufacturing
P.O. Box 415
Fairfield
IA 52556;
Dear Mr. Richard: This responds to your letter inquiring about the Federal safet standards that would apply to a product you are planning to sell. You stated that the product is a 6 inch by a 4 inch sheet of 1/8 inch thick semi-transparent rubber that is held on a side window of a vehicle by four suction cups. The purpose of the sheet is to shield vehicle occupants from the sun. The following discussion explains the applicability of our safety standards to your sun screen.; Pursuant to the National Traffic and Motor Vehicle Safety Act, we hav issued Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials,* (49 CFR 571.205) which specifies performance and location requirements for glazing used in vehicles. These requirements include specifications for minimum levels of light transmittance (70% in areas requisite for driving visibility, which includes all windows in passenger cars).; Any manufacturer, dealer or other person who installs tinting films o other sun screen devices, such as those described in your letter, in *new* vehicles must certify that the vehicle as altered, continues to comply with the requirements of the standard. Thus, for example, the light transmittance through the combination of the sun-screening material and the glazing must be at least 70 percent in the case of glazing used in windows requisite for driving visibility. Similarly, the combination must also meet the other applicable requirements of the standard, such as the abrasion resistance requirements.; After a vehicle is sold to the consumer, owners may alter thei vehicles as they please, so long as they adhere to all State requirements. Under Federal law, an owner may install any device regardless of whether the installation adversely affects light transmittance. The agency does, however, urge owners not to install equipment which would render inoperative the compliance of a vehicle with our standards. Individual States govern the operational use of vehicles by their owners and therefore it is within the authority of the States to preclude owners from applying sun screens on their vehicles.; If a manufacturer, dealer, distributor or motor vehicle repair busines installs the sun screen device for the owner of a used vehicle, then S108(a)(2)(A) of the Vehicle Safety Act may apply. That section provides that none of those persons may knowingly render inoperative any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with a Federal motor vehicle safety standard. Violation of the 'render inoperative' provision can result in Federal civil penalties of up to $1,000 for each violation.; I am enclosing the sample of your product you sent with your letter. I you need further information, the agency will be glad to provide it.; Sincerely, Jeffrey R. Miller, Chief Counsel