Interpretation ID: nht94-4.86

TYPE: INTERPRETATION-NHTSA

DATE: November 22, 1994

FROM: P. Binder -- ITT Automotive Europe

TO: John Womack -- Office of the Chief Counsel, NHTSA

TITLE: New Development of a Rearlamp

ATTACHMT: ATTACHED TO LETTER DATED 12/7/94 FROM PHILIP R. RECHT TO HERR P. BINDER (A42; REDBOOK 2; STD. 108)

TEXT: We have the following problem regarding the new development of a rearlamp:

The rearlamp will be fixed on a car which will be produced in Germany and exported to the USA.

The car manufacturer wants to have a yellow bulb for the function "turn signal lamp". Planned is the bulb type PY 21W. This is a yellow bulb (12V/21W) registered under ECE-R37 with a base BAU 15 (TEC-Publ. 61, Page 7004-19-1)-a data sheet is attached!

As far as we know there is only one comparable yellow bulb available in USA - the bulb Trade No. 1156 NA. This one has, however, a base S.C. Bayonet.

(GRAPHICS OMITTED)

May we ask you therefore to answer the following questions:

1) Is it allowed in USA that new rearlamps are fitted with such "Europe"-bulbs?

2) Do spare bulbs of the same type (PY 21W) have to be freely available in USA (e.g. supermarket, station, etc.)?

3) Would it be sufficient if the car manufacturer offers this bulb (PY 21W) as a spare part within his service stations in USA?

4) Is there any specification or law regarding the use of bulbs in USA? If so, please inform us about these specifications.

5) Is the use of bulbs treated differently in the single states?

As there is the possibility of changes in design of the rearlamp we would be grateful for an answer as soon as possible.

Thank you very much in advance for you help.