Interpretation ID: 22507.ztv

Mr. Peter Hoffman
President
I.D. Lite Products Group, Inc.
4645-A Southern Blvd.
West Palm Beach, FL 33415

Dear Mr. Hoffman:

This is in reply to your letter of December 4, 2000, to the Chief Counsel, requesting an interpretation relating to your "patented product for vehicles, specifically commercial trucks such as tow vehicles."

You identify the product as "designed to back light customer signage by simply sliding in an insert that can be made by any reputable sign shop." The power source is "via cigarette lighter plug or direct connect to any 12vdc source." This indicates to us that your product is intended for sale in the aftermarket to individual owners of motor vehicles for installation by them, rather than for sale as original equipment to manufacturers of motor vehicles who will install it before sale.

Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment specifies requirements for lighting equipment on motor vehicles. Under Standard No. 108, the color of light emitted from lamps must be white, red, or amber. The color of the light emitted by your product is green. Standard No. 108 would not permit a green lamp on a motor vehicle.

However, because your product is not required as original equipment on motor vehicles, we do not regulate its manufacture and sale as either original or aftermarket equipment. Because your product is intended for installation by vehicle owners, it is exempted from a law that might prohibit it if it were installed by a manufacturer, dealer, distributor, or motor vehicle repair business.

This means that the question as to the legality of its use is answerable under the laws of each State in which the product is likely to be used. We are unable to advise you on the laws of the individual States, but we believe that the color green may not be allowable in many of them.

I am enclosing for your information copies of three letters we have issued concerning devices which have similarities to your product (dated 5/4/00, to Mr. Browder, 8/13/93, to Mr. Ross, and 6/15/91, to Ms. Funk). The letters address additional issues which may be relevant to your product. (I note, however, that while the two earlier letters suggest contacting the American Association of Motor Vehicle Administrators for an opinion about State laws, that organization has advised us that they no longer provide such opinions.) I am also enclosing a copy of a paper titled "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment."

Sincerely,

John Womack
Acting Chief Counsel

Enclosures
ref:108
d.4/10/01