The National Highway Traffic Safety Administration has reversed its previous interpretation of federal lighting standards and has virtually cleared the way for vehicle headlamp replacement systems that are not from original equipment manufacturers of lamps and components. The NHTSA had previously asserted that replacement headlamps must meet all appropriate photometry requirements and use the same light source as the original equipment.

This earlier decision would have disallowed the replacement of a halogen-based system with high-intensity (HID) lamps that would otherwise have met all FMVSS 108 standards. NHTSA issued its first interpretation in draft opinion subject to public comment back in 2003 and stuck with it in a final October 2004 letter despite the objections of over 25 organizations and businesses.

The Specialty Equipment Market Association immediately appealed for reconsideration reasoning that the decision will inhibit the ability of aftermarket businesses to improve their vehicle lighting equipments. Finally, in a Nov 1, 2005 notice, NHTSA reversed its previous decision and agreed with the challenge from SEMA that the FVMSS 108 or Federal Motor Vehicle Safety Standard 108 is a performance standard that allows for replacement variations provided that an overall system will comply with specified photometry and functionality requirements.

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