White Paper: Manufacturing & Prototyping
Understanding FMVSS 108: A Practical Guide for Automotive Lamp Engineers
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This technical white paper offers a clear and comprehensive overview of FMVSS 108, the key regulation governing lighting and reflective devices for vehicles in the United States. Written specifically for lamp manufacturers and those responsible for certification, the guide walks through how to identify applicable requirements based on lamp function, system type, and installation context.
It breaks down FMVSS 108 into digestible sections covering signal lamps, headlighting systems, and retroreflective devices, with in-depth explanations of applicable tests such as photometry, vibration, ingress protection, and aim ability. Application examples illustrate how compliance strategies may differ for universal trailer lights versus sealed beam headlamp replacements. Special attention is given to recent developments such as Adaptive Driving Beams, and the white paper also compares U.S. and Canadian regulations.
The guide provides engineers with practical answers to frequently asked questions, including how many samples to test, how often to re-certify, and how to handle noncompliance. It also details what manufacturers need to submit for testing and how Intertek can support both early-stage development and final compliance.
If you are responsible for lighting design, product validation, or regulatory strategy, this guide will help you understand your responsibilities and streamline certification.
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Overview
The document is a comprehensive guide for lamp manufacturers regarding compliance with the Federal Motor Vehicle Safety Standard 108 (FMVSS 108), which sets minimum safety requirements for automotive lighting and reflective devices. Administered by the U.S. Department of Transportation's National Highway Traffic Safety Administration (NHTSA), FMVSS 108 applies to all original and replacement lamps for various vehicles, including passenger cars, trucks, buses, and motorcycles.
The guide begins with an introduction to FMVSS 108, explaining its significance in ensuring the safety of automotive lighting. It outlines the basic requirements that manufacturers must meet to certify their products, emphasizing the importance of compliance with applicable motor vehicle safety standards as mandated by Title 49 of the United States Code (USC) section 30115. This section states that manufacturers or distributors must certify that their equipment complies with safety standards, and they bear the responsibility for this certification.
The document details the testing process, highlighting that manufacturers should exercise "reasonable care" to ensure compliance. This involves maintaining quality control processes and conducting formal tests on their products. The guide provides practical advice on how many samples to test for certification, suggesting that manufacturers test a single part when results are robust, while multiple tests may be necessary when results are borderline. It also recommends that manufacturers test their products at least annually and whenever there are changes in manufacturing processes or materials.
Additionally, the guide addresses frequently asked questions, clarifying the responsibilities of manufacturers in certifying their parts and the role of third-party testing labs like Intertek. It emphasizes the importance of these labs in helping manufacturers navigate the complexities of compliance and ensuring that their products meet safety standards.
Overall, the document serves as a valuable resource for lamp manufacturers, offering insights into the certification process, testing requirements, and the critical role of quality assurance in the automotive lighting industry. It aims to equip manufacturers with the knowledge needed to successfully bring compliant and safe products to market.