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Interpretation ID: 22038


    Mr. Ronald E. Kish
    Plastics by Design
    P.O. Box 220
    Marcellus, MI 49067


    Dear Mr. Kish:

    This is in reply to a recent undated fax you sent Richard Van Iderstine of this agency about a license plate lamp design for a cargo utility trailer. The lamp would be mounted to the left of the door-mounted plate on the trailer frame.

    The standard that applies to your question is Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment. Standard No. 108 requires trailers to be equipped with a license plate lamp, or lamps, in accordance with SAE Standard J587 OCT81, License Plate Lamps (Rear Registration Plate Lamps), and located "at rear license plate, to illuminate the plate from the top or sides."

    Conventional license plate lighting systems consist of either one lamp illuminating the plate from the top, or two lamps illuminating the plate, one from each side. These systems are intended to ensure a reasonably uniform distribution of light on the surface of the plate. We are not conversant with the use of a single lamp to illuminate the plate from one side only. The lamp must comply with SAE J587 and we cannot determine from your two-dimensional drawing whether it does so. I enclose a copy of SAE J587 so that you may make this determination. I call your attention to Paragraph 6.5 which specifies that:

      When a single lamp is used to illuminate the plate, the lamp and license plate holder shall bear such relation to each other that at no point on the plate will the incident light make an angle of less than 8 deg. to the plate of the plate, this angle being measured from the edge of the light emitting surface of the device farthest from the surface of the plate.

    If you are asking whether a design is acceptable in which the lamp is mounted on a fixed part of the vehicle, and the lamp on a moveable part, our answer is yes, provided that SAE J587 is met. Compliance of the vehicle is determined with deck lids and doors shut.


    Sincerely,
    Frank Seales, Jr.
    Chief Counsel

    Enclosure

    NCC-20 ZTVinson:mar:8/25/00:62992:OCC 22038
    cc: NcC-01 Subj./Chron
    interps std. 108; redbook -2
    ztv; 22038; U:\ncc20\interp\108\22038.ztv