Interpretation ID: 17338.ztv

Mr. Michael Krumholz
2301 N.W. 33rd Court, Unit 104
Pompano Beach, FL 33069

Dear Mr. Krumholz:

This is in reply to your fax of February 11, 1998, to Taylor Vinson of this Office.

With respect to "the standards for blue and yellow fog and driving lamps under Federal law," you ask us to confirm your understanding that "these lights are allowed as long as they do not impair the effectiveness of the required lighting equipment for motor vehicles."

We are happy to confirm your understanding. Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment does not prescribe specifications for fog lamps or driving lamps, either as standard or optional equipment. This means that the individual states have the authority to regulate the performance of these lamps, and even to forbid them. Most if not all states regulate the color of auxiliary lamps, either directly or through reference to standards of the Society of Automotive Engineers. Those standards prescribe white to yellow as the permitted color and state how to measure it. Also, most states prohibit lamps from emitting blue light because that color is often reserved for police and emergency vehicles. I am sorry that we cannot advise you on the laws of the individual states. You will have to contact the Department of Motor Vehicles in each state for an answer.

Standard No. 108 prohibits supplementary original lighting equipment such as fog lamps or driving lamps if they impair the effectiveness of lighting equipment required by Standard No. 108. One example of impairment would be if a fog lamp were installed so close to a turn signal lamp (required by Standard No. 108) that its brightness masked the turn signal. To prevent this, front fog lamps must be located either more than 100 mm from a front turn signal lamp, or the turn signal must be up to 2.5 times more intense than otherwise required, depending on its distance from the fog lamp. See paragraph 5.1.5.4 of SAE Standard J588NOV84 Turn Signal Lamps for use on Motor Vehicles Less Than 2032 MM in Overall Width, incorporated by reference in Standard No. 108.

If you have any further questions, you may call Taylor Vinson (202-366-5263).

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d.4/8/98