Interpretation ID: nht93-5.19

TYPE: Interpretation-NHTSA

DATE: July 9, 1993

FROM: Margret Schmock von Ohr -- Robert Bosch GmbH

TO: Taylor Vinson -- Office of Chief Counsel, DOT

TITLE: Painted reflex reflectors for passenger cars

ATTACHMT: Attached to letter dated 10/13/93 from John Womack to Frau Margret Schmock von Ohr (A41; Std. 108)

TEXT:

This responds to my fax from May 3, 1993, Mr. Womack's reply from May 10, 1993 and our telephone call from today.

I had asked you whether it is permissible to paint reflex reflectors (exterior painting) for motor vehicles and under which conditions. Although you had already told me that it is permissible provided that all requirements of Standard 108 including the referenced SAE J594f are met I have to ask for further information.

1. Does the combination "Plastic + paint" have to meet SAE J576c? (Outdoor exposure test takes three!!!! years so that we cannot start our production now!)

2. Is it sufficient to have only the plastic material (without paint) tested according to SAE J576c?

3. If it is not sufficient how can we get an exception to the rule?

I want to highlight again that our production will be changed from painting to 2-color-molding in December 1993. Painting is only a transitional process!

Please protect this request as a confidential business information.

I would appreciate your response until next week.

Thank you very much in advance.