Interpretation ID: aiam2853
National Service Manager
Vespa of America Corporation
355 Valley Drive
Brisbane
CA 94005;
Dear Mr. Beyer: This is in reply to your letter of July 3, 1978, requesting a interpretation of Motor Vehicle Safety Standard No. 108, specifically, whether turn signal systems installed on mopeds must meet the standard's requirements. One of NHTSA's engineers has informally advised you, in your words, 'that because turn signal units on mopeds are not required devices...they are not required to meet the specific requirements in FMVSS 108 relative to motorcycles as long as they do not affect the operation of the other required equipment.'; We are pleased that Vespa is considering installing turn signal lamp on motor vehicles that S4.1.1.26 excuses from having them. If you wish to install systems that you intend to comply with Standard No. 108 and which for one reason or another fail to do so, it is doubtful that NHTSA would take any action against Vespa since the equipment is clearly optional and added only at a manufacturer's discretion. We would also view as preempted under Section 103(d) of the National Traffic and Motor Vehicle Safety Act any State action either to require turn signal lamps on mopeds or to establish requirements for such were they added at the option of the manufacturer.; I hope this clarifies the matter for you. Sincerely, Joseph J. Levin, Jr., Chief Counsel