Interpretation ID: nht71-5.17

DATE: 12/09/71

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Import-Export

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 20, 1971, to Mr. Franklyn Bergsman, National Highway Traffic Safety Administration, concerning your "Flash Mirrors."

As described in the documents you furnished to us, your "Flash Mirror" does not appear to impair the effectiveness of the required lighting equipment. If this is indeed the case, the use of your "Flash Mirrors" as original vehicle equipment is not prohibited by the Federal Motor Vehicle Safety Standard No. 108. Nor is there a Federal prohibition against sale of your device in the aftermarket; Standard No. 108 covers only specified replacement lighting equipment for vehicles manufactured on or after January 1, 1972.

Since your product is not regulated by Standard 108, the sale and use of it is, however, subject to the regulations of the individual States.