Interpretation ID: nht68-3.13

DATE: 02/09/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Electrographic Corporation

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of December 18, 1967, to Mr. Lowell K. Bridwell, you describe the procedure initiated by you for identifying and marking light hit containers. You ask for our acknowledgement of the procedure. It is not clear from your letter, but we gather that you manufacture truck bodies and ship light kits in a separate box, either to accompany or separate from the truck bodies.

The so-called "lighting Standard," Standard 103 of the initial Federal Motor Vehicle Safety Standards, to entitled "Lamps, Reflective Devices, and Associated Equipment." The standard applies to multipurpose passenger vehicles, trucks, trailers and buses, that are 80 or more inches wide overall, except pole trailers and converter dollies. It is the manufacturer of the completed vehicle who must certify that the vehicle conforms to all applicable Federal motor vehicle safety standards, including Standard No. 103. Unless the manufacturer of the lighting equipment and the completed vehicle are the same, the manufacturer of lighting equipment is not required to certify that such equipment conforms to Standard No. 103. It would seem logical to expect that the manufacturer of the completed vehicle would require from the manufacturer of the lighting equipment some indication that the lighting equipment is in conformity, but that is a matter to be settled between the two persons involved. Thus, while we have no objection to the procedure described in your letter, we do wish to emphasize that it does not relieve the vehicle manufacturer of insuring compliance and certifying to such compliance where appropriate.

Thank you for your interest. If further information is needed, please feel free to contact this office.