Interpretation ID: 86-3.23

TYPE: INTERPRETATION-NHTSA

DATE: 05/12/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Ms. Mary Fulton

TITLE: FMVSS INTERPRETATION

TEXT:

May 12, 1986 Ms. Mary Fulton Willas USA 8933 Quartz Avenue Northridge, California 91324 Dear Ms. Fulton: This is in reply to your letter of March 24, 1986, enclosing a brochure on your new product "TaleLights," and asking our "opinion of the product's legal standing." The brochure describes TaleLights as a "multi-message signboard" which is mounted "in the same rear window area where the new mandatory 'extra' brakelights are placed." TaleLights features automatically-activated messages such as "STOP," and manually activated ones such as "OOPS! SORRY." The Federal requirements for motor vehicle lighting (Federal Motor Vehicle Safety Standard No. 108) presently cover aftermarket lighting equipment only to the extent that it is intended to replace lighting equipment that is originally installed on a vehicle in compliance with Standard No. 108. We assume from your brochure that your product is intended for installation in vehicles not originally equipped with center high-mounted stop lamps, and under this assumption, your aftermarket product would not be covered by our requirements. It is, however, subject to the laws of each State in which it is to be sold and operated, and we suggest that you contact the motor vehicle administrators of States where you intend to market TaleLights. Your lamp is not an acceptable substitute for a center high-mounted stop lamp and it would be a violation of the National Traffic and Motor Vehicle Safety Act for a dealer, distributor, manufacturer, or motor vehicle repair business to remove a center high-mounted stop lamp and to replace it with TaleLights. Sincerely, Original Signed By Erika Z. Jones Chief Counsel