Interpretation ID: 24322.ztv

Mr. Jesus Cid
3139 Minonee Lane
Carson, NV 89701

Dear Mr. Cid:

Senator Reid has asked us to reply to your e-mail to him requesting information on the legality of neon lights "on the outside or inside" of your car.

I am enclosing copies of representative letters we have sent some other persons who asked this question. These are our letters of April 21, 1992, to Allan Schwartz of Tron Industries, and of July 29, 1993, to Charles D. Shipley, Director, Ohio Department of Public Safety. The views expressed in these letters remain unchanged today, in 2002 (however, the American Association of Motor Vehicle Administrators (AAMVA) no longer provides interpretations of State laws).

You did not specify the location on the outside of the car where you would like to install neon lights. The most frequent location appears to be under the car, and the letters we are sending you address underbody neon lighting. However, these letters do not cover neon lighting in the interior (see discussion below).

Federal law permits you as a vehicle owner to modify your vehicle personally in any way you wish. However, these modifications are subject to State law. We are not conversant with State laws, and, specifically, we do not know whether neon lighting on or in a motor vehicle is permitted by Nevada. We suggest that you call your local office of the Department of Motor Vehicles.

If the neon lighting is to be installed by a person other than yourself (specifically, a manufacturer, distributor, dealer, or motor vehicle repair business), there is an applicable provision of Federal law. This law is intended to ensure that the performance of original equipment installed as required by a Federal motor vehicle safety standard is not diminished by modifications after the vehicle is first sold. To avoid violating this law, the installer of the neon lighting should determine that its use would not have a negative effect upon the performance of the vehicle's original lighting equipment which has been installed, as required, by a Federal motor vehicle safety standard (or any other equipment installed in accordance with such a standard). For example (see our letter to Mr. Schwartz), the intensity of neon lights on the exterior should not mask the intensity of turn signal and stop lamps. A neon light in the interior should not be placed in the rear parcel shelf to avoid confusion and diminishing the effect of the center highmounted stop lamp. Even if you and the installer decide that the neon lighting you desire would not have a negative effect upon the performance of other lamps, the legality of neon lighting remains subject to the laws of Nevada, or any other State where the car is driven.

Sincerely,
Jacqueline Glassman
Chief Counsel
Enclosures
ref:108
d.5/17/02