New LED tail lights 69 Cuda
We design our light panels to the meet the standards of DOT and SAE for lighting.
That's a good start, but do you
test and certify, as you are required by law to do, that your lights meet the applicable provisions of FMVSS 108? Whether or not you replace the lens or reflector doesn't change your obligation; in fact, your retaining the original lens and/or reflector subjects you to additional requirements that your product not "render inoperative" a regulated item, system, or feature. That phrase "render inoperative" is in quotes because it means more than it looks like it means. It's not enough that your product retain all the same functions as the bulb it replaces. It must also maintain the compliant performance of the device. If any function (e.g., taillamp function, stop lamp function, etc.) does not meet all applicable requirements, then you have "rendered inoperative" that function.
This is a direct question and I would like a direct answer, please, because automotive lighting technical standards development and assessment is a major part of what I do for a living, and it looks to me as if your Barracuda lamps might not meet the applicable requirements. I'm not involved in enforcement of the Federal regulations, so I have no power or desire to smack you with the
exceedingly stiff civil penalties of $6K per violation (1 lamp = 1 violation) NHTSA can assess and collect from manufacturers or importers of noncompliant lamps. It's just that if I'm going to buy these — and I am considering buying some of your lights for at least one of my cars — I need to know whether or not they are manufacturer-certified as complying with all applicable provisions of FMVSS 108, because that is what determines their legality and the adequacy of their safety performance. Practically speaking, it matters. Maybe not today or tomorrow or next week, but it will Matter with an uppercase M (and uppercase dollar signs) in the event a crash happens and the nonstandard lights are discovered.
These aren't toys or Xmas tree lights we're talking about, they're regulated items of vehicle safety equipment. Sure, yours look cool. You say you design them to conform to the applicable standards. Can you prove it? Will you?
