Interpretation ID: nht81-1.30

DATE: 03/05/81 EST

FROM: FRANK BERNDT -- NHTSA CHIEF COUNSEL

TO: P. SOARDO -- ISTITUTO ELETTROTECNICI NAZIONALE GALILEO FERRARIS TORINO, ITALY

COPYEE: AMERICAN ASSOCIATION OF MOTOR VEHICLE ADMINISTRATION

TITLE: NOA-30

ATTACHMT: LETTER DATED 11/28/80 FROM P. SOARDO TO NHTSA RE REAPPROVAL OF LIGHTING DEVICES, FEDERAL STANDARD 108

TEXT: Dear Professor Soardo:

Your letter of November 28, 1980 has just arrived, in which you asked about State approval of lighting devices.

Each State has its own requirements and method of proceeding, and these are independent of U.S. governmental requirements. Therefore, I regret to say, we are unable to answer this question, and it should be asked of the particular State in which you have an interest. However, the American Association of Motor Vehicle Administration may be able to answer this question and we are sending a copy of your letter to it for direct reply.

You have also asked what Motor Vehicle Safety Standard No. 108 requires "when a car is no longer manufactured, but... lighting devices are available as spare parts". Standard No. 108 applies not only to motor vehicles but also requires compliance of lighting equipment manufactured to replace lighting equipment originally installed on a motor vehicle pursuant to Standard No. 108.

Sincerely,