A Primer on FMVSS 108
Note to moderator: Please consider making this a Sticky in the “Lighting” section of the “DIY” section.
1) INTRO:
I have written this primer to provide some answers to the question: Are Headlight and Taillight Modifications Legal?
The simplest answer is “No, such mods are NOT legal.”
A more accurate answer is that some mods are legal, but most of them are not, and in some cases it will depend on state and local laws.
If you are of a mind to perform a mod and you don’t really care if it is legal or not, then you don’t need to read any further. But consider this first: If you modify your lighting and you are involved in a collision, your modifications will likely cause you to take on a larger portion of the blame for the collision. For example, if you perform a mod that alters the beam pattern of your turn signal, don’t be surprised when the other party’s lawyer says that his client didn’t see your turn signal flashing because it was an illegal turn signal.
2) MY BACKGROUND
I am not a lawyer. Do not consider anything I have written to be legal advice. It is not.
What I am is a mechanical engineer with several years experience designing light bulbs for General Electric Lighting, and then designing headlights and taillights for Grote Industries. I know a great deal about halogen, HID, and LED technologies, and I know a great deal about reflector optics and lens optics for motor vehicles.
3) FMVSS 108, Oct 1, 2004.
Federal Motor Vehicle Safety Standard 108 is a set of federal laws that MUST be met by motor vehicle manufacturers (both OEM and aftermarket). This statute not only specifies what SAE standards must be met, but also the testing methodologies that are acceptable. It is not enough for a lighting manufacturer to claim that their product meets 108, but they must have documented proof of testing done to justify their claim. Having met 108, the manufacturer can then legally place markings on the lens that indicate the lamps meet certain specifications.
It could be argued that FMVSS 108 applies to manufacturers but not to consumers (DIY mods). Most states have laws to close that loop hole.
Some lighting manufacturers are unscrupulous or lazy, and will mark their products as meeting 108 when in fact their products do not. It is not reasonable for a consumer to have the knowledge or equipment to verify this, but some false claims are easy to spot. For example, it you buy an aftermarket headlamp or taillamp that doesn’t have any amber or red reflectors and the OEM headlamps and taillamps did have reflectors, then you are looking at an illegal light.
The best resource I have found online is:
FMVSS No. 108 Home Page
This web site was last updated in 2002, and has a few sections that are labeled as “under construction.” Since the site has not been updated in seven years, I wouldn’t hold my breath waiting for it to be finished. However, the parts that are complete are very useful.
Other good sources:
http://www.ntea.com/uploadedFiles/N...urces/Lighting_Guide/fmvss_lighting_chart.pdf
Links to complete FMVSS No. 108 (2004 edition) | Specialty Equipment Market Association
Note that lighting manufacturers don’t like making a different product for each state. Thus, the most stringent laws in any state tend to be adopted by the manufacturers so that one version of their product is legal in all 50 states. California tends to have the most stringent laws, and thus California indirectly drives how vehicle lights are made. Canadian laws also influence design. Again, it is better to have one product that can fit several markets rather than specializing.
SAE (the Society of Automotive Engineers) have written standards for vehicle lighting. These SAE standards are not laws. However, there are laws that make meeting those SAE standards mandatory.
NHTSA (The National Highway Transportation Safety Administration) administers laws for motor vehicle safety. These are the guys who can force recalls when manufacturers drag their feet. NHTSA is deeply involved in the wording of regulations for vehicle lighting.
FMVSS is boring. I’ll summarize below the sections of FMVSS 108 apply to an 8th gen Civic:
Motor vehicles less than 80 inches wide (meaning the 8th gen Civic) MUST have the following lighting devices that meet the SAE standard listed next to it below. Each SAED standard has a date associated with it that represents the date that particular version was published by SAE. If SAE creates a new version, the new version is not legally binding unless FMVSS 108 is amended to require that latest version. This list was accurate as of Oct 1, 2004.
Headlamps (SAE J566, Jan 1960).
2 red taillamps (SAE J585e, Sep 1977).
2 red stop lamps (SAE J586, Feb 1984).
1 red high-mounted stop lamp (SAE J186a, Sep 1977).
1 white license plate lamp (SAE J587, Oct 1981).
2 amber OR white parking lamps (SAE J222, Dec 1970).
2 red rear, 2 red side, and 2 amber side Reflex reflectors (SAE J594f, Jan 1977).
2 red and 2 amber side marker lamps (SAE J592e, Jul 1972).
1 white backup lamp (SAE J593c, Feb 1968).
2 red or 2 amber rear turn signal lamps (SAE J588, Nov 1984).
2 amber front turn signal lamps (SAE J588, Nov 1984).
Your 8th gen Civic left the factory with all of the above lighting devices. It is a safe bet that removing any of them makes the car illegal.
Note that the colors are not arbitrary. Defining the color of light (especially white) can be complex. Suffice it to say here that there are scientific definitions of “red,” “amber,” and “white,” and that just because an aftermarket product “looks right” to you doesn’t mean that it meets the color defined in the SAE standards.
4) MARKINGS
This is what the markings on the lenses of headlamps and taillamps mean:
DOT A headlamp’s beam pattern meets FMVSS 108 specifications.
A Reflex reflector, meeting standard SAE J594f
I Turn signal lamp, meeting standard SAE J588
R Backup lamp, meeting SAE J593c
S Stoplamp, meeting SAE J586
T Taillamp, meeting SAE J585e
P2 Side marker lamp, meeting SAE J592e
5) “CLEARING” HEADLAMPS
If you remove the amber reflector, you no longer have a legal car. An amber side reflector is required to be towards the front of the vehicle, and a red side reflector is required to be towards the rear of the vehicle. You can add a side reflector (say, on the bumper) to fill the function of the side reflector that was inside the headlamp, but if it is too small, then you still don’t have a legal vehicle. If you want to go that route, look for a letter “A” on the surface of the reflector, which indicates that it meets SAE J594f.
If you remove the amber lens that is over the turn signal bulb, you have an illegal vehicle for three reasons. (1) Note the optics on the amber lens that are facing forward. These optics are for the turn signal function. If you remove them, you have an illegal beam pattern. (2) The turn signal on the 8th gen Civic is serving two functions: It is a turn signal and it is a side marker. Note the optics that are along the side of the bulb. These are your side marker optics. If you remove these optics, you have an illegal side marker light. (3) The side marker and the turn signal must be amber. You can install an amber bulb, but you still have the two problems listed above.
6) HID HEADLAMPS
If you take out your halogen bulb and slap in an HID bulb, I guarantee you that you will have an illegal beam pattern. The HID bulb is brighter, and the arc source is a smaller light source than the halogen’s filament wire. The reflector must be designed for the light bulb. There is no such thing as one reflector that will give a legal beam pattern for two different bulbs. Even if the beam pattern “looks” like it has the correct shape, there will be too much light thrown into the eyes of oncoming drivers. A well-engineered HID system is unmistakable – it doesn’t blind oncoming drivers.
If you want HID and you want to stay legal then you have two choices: (1) Buy a complete headlamp assembly that was designed around an HID bulb (the reflector was designed for HID). (2) Cut a big hole in the OEM reflector and retrofit an HID projector headlight into the hole. The beam pattern from a low-beam projector system is a legal low-beam beam pattern.
7) TINTED HEADLIGHT COVERS
Yep, you guessed it: Illegal. If you put anything at all between your head lights and the road, you have an illegal head light. Same goes for tinted tail lights and tail light covers. You are decreasing the light output, and thus have modified the beam pattern. It is theoretically possible to put a tint over a headlamp and still have a legal pattern, but you don’t own the high-dollar photometric measuring equipment to prove it.
8) BLUE-TINTED HALOGEN BULBS
Yes, they are legal if the package says they meet FMVSS 108 (they have the appropriate light output and have a legal color). That doesn’t mean that a state or locality can’t outlaw them. Check your local laws.
Besides legal stuff, there is an engineering side to this argument. If you take a white light and stick a blue filter in front of it, you will have less light. But if the bulb makes less light, then it doesn’t meet FMVSS 108. For example, if a 9006 low beam bulb has less than 1000 lumens (+/- 15%), it can’t be labeled as a “9006.” So what does the light bulb manufacturer do? They design the filament so that it burns brighter (more lumens) so that when you stick a blue filter on it, the end result is the correct amount of light. But there is a penalty. A standard halogen bulb has a life of 1000 hours. A blue-tinted halogen bulb has a life of only 200 hours. So, do you still want those blue light bulbs that cost more and that you will be replacing five times as often?
9) ACCESSORY AFTERMARKET LIGHTING
If you are adding lighting in addition to the lighting that the car had when it left the factory, then you will have to look up your state and local laws. FMVSS 108 does not touch upon the subject of accessory lighting (like neon under the car or LED lights around the license plate), though it does cover fog lamps.
Note to moderator: Please consider making this a Sticky in the “Lighting” section of the “DIY” section.
1) INTRO:
I have written this primer to provide some answers to the question: Are Headlight and Taillight Modifications Legal?
The simplest answer is “No, such mods are NOT legal.”
A more accurate answer is that some mods are legal, but most of them are not, and in some cases it will depend on state and local laws.
If you are of a mind to perform a mod and you don’t really care if it is legal or not, then you don’t need to read any further. But consider this first: If you modify your lighting and you are involved in a collision, your modifications will likely cause you to take on a larger portion of the blame for the collision. For example, if you perform a mod that alters the beam pattern of your turn signal, don’t be surprised when the other party’s lawyer says that his client didn’t see your turn signal flashing because it was an illegal turn signal.
2) MY BACKGROUND
I am not a lawyer. Do not consider anything I have written to be legal advice. It is not.
What I am is a mechanical engineer with several years experience designing light bulbs for General Electric Lighting, and then designing headlights and taillights for Grote Industries. I know a great deal about halogen, HID, and LED technologies, and I know a great deal about reflector optics and lens optics for motor vehicles.
3) FMVSS 108, Oct 1, 2004.
Federal Motor Vehicle Safety Standard 108 is a set of federal laws that MUST be met by motor vehicle manufacturers (both OEM and aftermarket). This statute not only specifies what SAE standards must be met, but also the testing methodologies that are acceptable. It is not enough for a lighting manufacturer to claim that their product meets 108, but they must have documented proof of testing done to justify their claim. Having met 108, the manufacturer can then legally place markings on the lens that indicate the lamps meet certain specifications.
It could be argued that FMVSS 108 applies to manufacturers but not to consumers (DIY mods). Most states have laws to close that loop hole.
Some lighting manufacturers are unscrupulous or lazy, and will mark their products as meeting 108 when in fact their products do not. It is not reasonable for a consumer to have the knowledge or equipment to verify this, but some false claims are easy to spot. For example, it you buy an aftermarket headlamp or taillamp that doesn’t have any amber or red reflectors and the OEM headlamps and taillamps did have reflectors, then you are looking at an illegal light.
The best resource I have found online is:
FMVSS No. 108 Home Page
This web site was last updated in 2002, and has a few sections that are labeled as “under construction.” Since the site has not been updated in seven years, I wouldn’t hold my breath waiting for it to be finished. However, the parts that are complete are very useful.
Other good sources:
http://www.ntea.com/uploadedFiles/N...urces/Lighting_Guide/fmvss_lighting_chart.pdf
Links to complete FMVSS No. 108 (2004 edition) | Specialty Equipment Market Association
Note that lighting manufacturers don’t like making a different product for each state. Thus, the most stringent laws in any state tend to be adopted by the manufacturers so that one version of their product is legal in all 50 states. California tends to have the most stringent laws, and thus California indirectly drives how vehicle lights are made. Canadian laws also influence design. Again, it is better to have one product that can fit several markets rather than specializing.
SAE (the Society of Automotive Engineers) have written standards for vehicle lighting. These SAE standards are not laws. However, there are laws that make meeting those SAE standards mandatory.
NHTSA (The National Highway Transportation Safety Administration) administers laws for motor vehicle safety. These are the guys who can force recalls when manufacturers drag their feet. NHTSA is deeply involved in the wording of regulations for vehicle lighting.
FMVSS is boring. I’ll summarize below the sections of FMVSS 108 apply to an 8th gen Civic:
Motor vehicles less than 80 inches wide (meaning the 8th gen Civic) MUST have the following lighting devices that meet the SAE standard listed next to it below. Each SAED standard has a date associated with it that represents the date that particular version was published by SAE. If SAE creates a new version, the new version is not legally binding unless FMVSS 108 is amended to require that latest version. This list was accurate as of Oct 1, 2004.
Headlamps (SAE J566, Jan 1960).
2 red taillamps (SAE J585e, Sep 1977).
2 red stop lamps (SAE J586, Feb 1984).
1 red high-mounted stop lamp (SAE J186a, Sep 1977).
1 white license plate lamp (SAE J587, Oct 1981).
2 amber OR white parking lamps (SAE J222, Dec 1970).
2 red rear, 2 red side, and 2 amber side Reflex reflectors (SAE J594f, Jan 1977).
2 red and 2 amber side marker lamps (SAE J592e, Jul 1972).
1 white backup lamp (SAE J593c, Feb 1968).
2 red or 2 amber rear turn signal lamps (SAE J588, Nov 1984).
2 amber front turn signal lamps (SAE J588, Nov 1984).
Your 8th gen Civic left the factory with all of the above lighting devices. It is a safe bet that removing any of them makes the car illegal.
Note that the colors are not arbitrary. Defining the color of light (especially white) can be complex. Suffice it to say here that there are scientific definitions of “red,” “amber,” and “white,” and that just because an aftermarket product “looks right” to you doesn’t mean that it meets the color defined in the SAE standards.
4) MARKINGS
This is what the markings on the lenses of headlamps and taillamps mean:
DOT A headlamp’s beam pattern meets FMVSS 108 specifications.
A Reflex reflector, meeting standard SAE J594f
I Turn signal lamp, meeting standard SAE J588
R Backup lamp, meeting SAE J593c
S Stoplamp, meeting SAE J586
T Taillamp, meeting SAE J585e
P2 Side marker lamp, meeting SAE J592e
5) “CLEARING” HEADLAMPS
If you remove the amber reflector, you no longer have a legal car. An amber side reflector is required to be towards the front of the vehicle, and a red side reflector is required to be towards the rear of the vehicle. You can add a side reflector (say, on the bumper) to fill the function of the side reflector that was inside the headlamp, but if it is too small, then you still don’t have a legal vehicle. If you want to go that route, look for a letter “A” on the surface of the reflector, which indicates that it meets SAE J594f.
If you remove the amber lens that is over the turn signal bulb, you have an illegal vehicle for three reasons. (1) Note the optics on the amber lens that are facing forward. These optics are for the turn signal function. If you remove them, you have an illegal beam pattern. (2) The turn signal on the 8th gen Civic is serving two functions: It is a turn signal and it is a side marker. Note the optics that are along the side of the bulb. These are your side marker optics. If you remove these optics, you have an illegal side marker light. (3) The side marker and the turn signal must be amber. You can install an amber bulb, but you still have the two problems listed above.
6) HID HEADLAMPS
If you take out your halogen bulb and slap in an HID bulb, I guarantee you that you will have an illegal beam pattern. The HID bulb is brighter, and the arc source is a smaller light source than the halogen’s filament wire. The reflector must be designed for the light bulb. There is no such thing as one reflector that will give a legal beam pattern for two different bulbs. Even if the beam pattern “looks” like it has the correct shape, there will be too much light thrown into the eyes of oncoming drivers. A well-engineered HID system is unmistakable – it doesn’t blind oncoming drivers.
If you want HID and you want to stay legal then you have two choices: (1) Buy a complete headlamp assembly that was designed around an HID bulb (the reflector was designed for HID). (2) Cut a big hole in the OEM reflector and retrofit an HID projector headlight into the hole. The beam pattern from a low-beam projector system is a legal low-beam beam pattern.
7) TINTED HEADLIGHT COVERS
Yep, you guessed it: Illegal. If you put anything at all between your head lights and the road, you have an illegal head light. Same goes for tinted tail lights and tail light covers. You are decreasing the light output, and thus have modified the beam pattern. It is theoretically possible to put a tint over a headlamp and still have a legal pattern, but you don’t own the high-dollar photometric measuring equipment to prove it.
8) BLUE-TINTED HALOGEN BULBS
Yes, they are legal if the package says they meet FMVSS 108 (they have the appropriate light output and have a legal color). That doesn’t mean that a state or locality can’t outlaw them. Check your local laws.
Besides legal stuff, there is an engineering side to this argument. If you take a white light and stick a blue filter in front of it, you will have less light. But if the bulb makes less light, then it doesn’t meet FMVSS 108. For example, if a 9006 low beam bulb has less than 1000 lumens (+/- 15%), it can’t be labeled as a “9006.” So what does the light bulb manufacturer do? They design the filament so that it burns brighter (more lumens) so that when you stick a blue filter on it, the end result is the correct amount of light. But there is a penalty. A standard halogen bulb has a life of 1000 hours. A blue-tinted halogen bulb has a life of only 200 hours. So, do you still want those blue light bulbs that cost more and that you will be replacing five times as often?
9) ACCESSORY AFTERMARKET LIGHTING
If you are adding lighting in addition to the lighting that the car had when it left the factory, then you will have to look up your state and local laws. FMVSS 108 does not touch upon the subject of accessory lighting (like neon under the car or LED lights around the license plate), though it does cover fog lamps.