Disagree.
Surprise!
What document do you derive the explicit requirement of having to be on
AMECA's list of acceptable plastics before it can be used?
Check NHTSA interp files for the last ten years. This is why Hella wasn't
permitted to market their "magic colours" aftermarket taillamps with outer
lenses of green, blue, etc. The lamps emit all the correct light colours
as required per function, but because there are (or at the time were) no
approved green or blue (etc) plastic materials on the list, NHTSA's Chief
Counsel said "No" to Hella's RFI. A similar thing happened with the
first-design Audi A8, which for one year only in the US was equipped with
rear combination lamps similar in design to those used in Europe: An
all-red appearance was achieved by using an outer lens of "rose red"
plastic and a green plastic balloon over the colourless bulb for the rear
directional indicators. Through subtractive filtration, this combination
produces amber light. However, at the time one or both of those materials
were absent from the approved-materials list, so to satisfy NHTSA's
"please knock it off" request, the rear directional indicator was changed
to a conventional red lens over colourless bulb, as a running change in
production.
The manufacturers in the US are responsible for self certifying their
components to the regulations.
Certainly, but remember, a great deal of the US regulatory give-and-take
of compliance and enforcement is achieved on a much less formal basis in
North America than in Europe. Frequently there will be dialogues,
sometimes extensive ones, between NHTSA and a manufacturer when some
aspect of a lighting device's construction or performance falls in one or
another type of grey area. Often, these dialogues are resolved informally
(e.g., NHTSA asks the manufacturer to change something and the
manufacturer agrees, without there being a formal recall, issuance of
interpretation or change to the regulations).
Are you saying that NHTSA physically pays and directs AMECA to certify
these plastics?
Oof...please don't feed me words, thanks; I just ate. *urp*
I stick by the statement that NHTSA operates as a rulemaking body, not
an approval body.
That is true *for the most part*; US auto safety regulations are generally
administered on an autocertification basis rather than a type approval
basis, but there are exceptions. How else do you explain 49CFR564?
DS