Interpretation ID: 23499.ztv

Mr. Galen Chen
Marketing Department
Maxzone Vehicle Lighting Corp.
5100 Walnut Grove Avenue
San Gabriel, CA 91776

Dear Mr. Chen:

This is in reply to your email of August 6, 2001. You wrote:

Some of the performance type corner lamps installed on cars are not street legal because of the white and clear color on them. Another word, they are lacking the amber color reflector. If these corner lamps are packaged with a reflector to be installed on the 2 side of the front bumper, can they be sold as street legal lamps?

We are uncertain what you mean by a "corner lamp;" no such lighting device is required or defined by Federal law. We surmise that the lamp to which you refer is one that is intended to replace a lamp that is original equipment on a motor vehicle, and that the original lamp incorporated an amber reflex reflector intended as a side reflex reflector mounted at the front side of a motor vehicle. The replacement lamp you refer to would not incorporate an amber reflex reflector but the package would include a separate amber reflector.

Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment, establishes requirements for motor vehicle lighting and for replacement lighting equipment. All motor vehicles are required to be equipped with an amber reflex reflector located on the front side of a vehicle. For purposes of this interpretation, we shall assume that the reflex reflector pictured in the attachment to your email is one that is certified as conforming to Standard No. 108. The question your letter presents, then, is whether, whether a replacement lamp must incorporate all the functions of the original equipment lamp it is intended to replace..

Paragraph S5.8 of Standard No. 108, Replacement equipment, requires that "each lamp, reflective device, or item of associated equipment manufactured to replace any lamp, reflective device, or item of associated equipment on any vehicle to which [Standard No. 108] applies, shall be designed to conform to [Standard No. 108]. (S5.8.1).

We do not read this requirement as allowing a package containing a lamp and a separate conforming reflector, when the original equipment lamp and reflector comprised an integrated unit. If the original equipment lamp incorporated a reflex reflector designed to conform to Standard No. 108, then the replacement lamp must also incorporate a conforming reflex reflector in order to satisfy S5.8.

Sincerely,

John Womack
Acting Chief Counsel

ref:108
d.12/14/01