Interpretation ID: nht71-4.40

DATE: 11/05/71

FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA

TO: Truck-Lite Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 14, 1971, to Mr. Lewis Owen of this Office concerning an interpretation regarding your Truck-Lite No. 127 License plate light.

The requested interpretation concerns the 8 degree incident light angle specified in SAE J587, "License Plate Lamps," as follows:

"When a single lamp is used to illuminate the plate, the lamp and license plate holder shall bear such relation to each other that at no point on the plate will the incident light make an angle of less than 8 deg to the plane of the plate."

Since the 8 degree incident light angle is also a requirement of Federal Motor Vehicle Safety Standard No. 108, all license plate lamp designs must conform to it. It is our position that the angle be measured from the optical center of the lens; therefore, the Electrical Testing Laboratories' position is valid. That is, the incident light angle of your lamp, without the paint shield and when mounted as it will be installed on the vehicle, is below the 8 degree minimum requirement.