Officer Ron Weeks

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This document retrieved from the NHTSA legal interpretations database.

Officer Ron Weeks
Biloxi Police Department
1045 Howard Avenue
Biloxi, MS 39530

Dear Officer Weeks:

We are replying to your email of February 15, 2000, to our Webmaster, asking for information about the substitution of" white" ( clear) lenses on the taillamps of motor vehicles. You report that officers in your locale have started citing drivers of vehicles with white lenses for improper equipment.

As you know, Federal requirements for original and replacement motor vehicle lighting equipment are established by 49 CFR 571.108 Standard No. 108, Lamps, Reflective Devices, and Associated Equipment. Under the preemption authority of 49 U.S.C. 30103(b), Mississippi may enact and enforce its own motor vehicle lighting equipment standard, provided that it is identical to Standard No. 108.

Table I and Table III of Standard No. 108 require taillamps and stop lamps to be red in color. The color red is defined by SAE Standard J578c Color Specifications for Electric Signaling Devices, February 1977 which S5.1.5 of Standard No. 108 incorporates by reference. Although Standard No. 108 does not specifically say that the lens must be red and the bulb clear to achieve the color red, we know of no original equipment manufacturer who is producing and certifying compliance with Standard No. 108 of a taillamp consisting of a red bulb and a white (clear) lens. Nor do we know of any red bulb in production that conforms to Standard No. 108's color specification.

In addition, if any replacement lens is plastic, S5.1.2 requires the plastic material to conform to the specifications of SAE Recommended Practice J576 Plastic Materials for Use in Optical Parts, Such as Lenses and Reflectors, of Motor Vehicle Lighting Equipment, JUL91. Since conformance is judged through a three-year outdoor exposure test, we have substantial doubts that any aftermarket white (clear) plastic lens intended for use on taillamps is manufactured from materials that have been tested in accordance with SAE J576 JUL91. Finally, it has been our experience that most white (clear ) replacement taillamp lenses do not incorporate a red side or rear reflex reflector as contained in the original red taillamp lens. Many vehicle manufacturers use the configuration of a red lens incorporating a reflex reflector to meet the additional requirement of Table I and Table III that vehicles be equipped with two red reflex reflectors on the rear, and one on each side at the rear.

For all the above reasons, we believe it likely that the use of white (clear) replacement lenses and red bulbs will result in a taillamp that does not comply with the specifications of Standard No. 108 for taillamps.

We hope that this information is helpful in your enforcement efforts. If you have any questions, you may call Taylor Vinson of this Office (202-366-5263).

Frank Seales, Jr.
Chief Counsel


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This site is not affiliated with any Federal, State, or Local organization.  The goal is to be as factual as possible, however, the views expressed on this site are the opinions of the author and should not be used to determine the legality of motor vehicle equipment in accordance with Federal laws.  If you require a legal interpretation of your specific situation concerning FMVSS No. 108, you should contact the National Highway Traffic Safety Administration's Office of Chief Counsel.