Ban Blinding Headlights! NHTSA Request for Public Comments on Committee Creation

Dear Supporters,

NHTSA has initiated a rulemaking process for updating the FMVSS-108 standards for vehicle headlamps.  The first step is that NHTSA has proposed that a committee of up to 18 people be created to develop the revised standards. (https://public-inspection.federalregister.gov/2026-20648.pdf).  This is a critical first step, but we already have concerns about this proposed committee.

Here is the proposed composition of the committee:

- Four representatives from vehicle lighting manufacturers or lighting retailers;
- Two representatives from national motor vehicle manufacturers;
- Four representatives from national motor vehicle or motor vehicle equipment
manufacturing associations;
- Two representatives from national motor vehicle or motor vehicle equipment safety
organizations;
- Three representatives from educational institutions or research institutions, or testing
organizations within the United States; and
- Three representatives from national professional engineering associations or standard
setting associations.

There will also be one representative from NHTSA.  The glaring omission here is the absence of a representative from the Food and Drug Administration.  This oversight must be corrected immediately.  The second omission is the absence of a representative from the public.  The third omission is a representative for disability rights.

The proposed topics for the committee are:  glare caused by headlighting systems, replaceable light sources, dusk sensors, plastic optical materials, semiautomatic beam switching, minimum lamp size requirements, lower beam photometry, upper beam photometry, on-vehicle headlamps performance that considers aim and mounting height, auxiliary lamp requirements, three-wheel motorcycle installation requirements, obsolete physical test requirements for associated equipment, physical test procedures for lamps that use replaceable lenses, and harmonization to international standards.

Missing from the topics list: restrictions on blue wavelength light, establishing an overall limit on intensity, standards for source size and luminance, restrictions on flicker and PWM, enforcement mechanism for illegal aftermarket lamps, explicit requirement for steady burning auxiliary lamps and enforcement mechanism, and eliminating the 0.5 degree retry testing loophole when measuring maximum intensity.

NHTSA is currently accepting comments and applications for committee members at this email address: (lightingfac@dot.gov).  I encourage each supporter to write to NHTSA at this email address and express your concerns about the proposed composition of the committee, and to request that the committee contain a representative from the FDA, a representative from the public, and a representative for disability rights, and that the topics list should include those that I listed above.

Sincerely,

Mark Baker
President
Soft Lights Foundation
www.softlights.org
mbaker@softlights.org
X: @softlights_org
Bluesky: @softlights-org.bsky.social