Interpretation ID: nht73-1.27

DATE: 05/25/73

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Truck Equipment & Body Distributors Association

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of May 14, 1973, you present the fact situation of an equipment manufacturer who installs lighting equipment on a component which he supplies to distributors or dealers, for installation by them on motor vehicles. For purposes of this letter, I assume that the installation occurs before the first sale of the vehicles for purposes other than resale. You ask what the equipment manufacturer should do to advise the distributor or dealer "that the lamps and/or reflectors which he has affixed to his product meets the published S.A.E. specs required by Standard 108."

There is no Federal requirement that an equipment manufacturer in this fact situation supply compliance information, although covered equipment that he sells must continue to conform. The requirements for certifying or otherwise providing information concerning conformity with Standard No. 108 apply to the manufacturer of the lighting equipment, and the manufacturer(s) (final-stage and others) of the vehicle in question. It may well be that the customers of the supplier you describe will demand assurances of conformity through commercial channels.

Yours truly, Mr.

Richard B. Dyson Assistant Legal Council, National Highway Traffic Safety Adm., Department of Transportation Washington, D.C. 20591

Good morning, Dick!

One of our members, who is a bumper manufacturer, has asked for the correct procedure he should use when supplying a license plate lamp for the rear bumper which he produces and sells to distributors and dealers.

I can't see that he would be required to report his production of this bumper, since the unit itself is not covered by a Safety Standard. It would seem however, that he should provide some sort of data regarding the S.A.E. specs of the lamp which he places in the bumper.

Now that I think about it, this is really no different than the body manufacturer who supplies lamps and reflectors as a part of his body or body kit, which could open a whole can of worms. Therefore, I need to rephrase my question to include all lamps and reflectors which manufacturers provide Final-stage Manufacturers. Based upon the above, what must a prudent manufacturer do, if anything, to advise the Final-stage Manufacturer that the lamps and/or reflectors which he has affixed to his product meets the published S.A.E. specs required by Safety Standard 108?

Thaks in advance for your cooperation with this matter.

Best regards,

THOMAS S. PIERATT--

Executive Secretary