The recent (attached) letter sent to me by NHTSA’s new Chief Counsel, Mr. Anthony Cooke, affirms my statements that indeed, the 7-3/4in² and 11-5/8in² “Effective Projected Luminous Lens Area” (EPLLA) mandates* spelled out in
Federal Motor Vehicle Safety Standard #108 are indeed, “The Law of the Land”, which dictates how much … and over what areas … all Brake and Turns Signals Outputs required to be designed and tested to.  Note that this Law pertains to “LED” Designs, as well as to Incandescent Designs. 

*Even though not mentioned … this also applies to the 4.5in² - EPLLA mandate for CHMSLs as well.

Mr. Cooke states that it is unlawful for Dealers to sell any vehicle or vehicle equipment that does not meet applicable
NHTSA standards.  Although he only refers to Dealers, this of course, includes everyone involved in the chain of Distribution
for supplying the public.

He also points out that the Office of Vehicle Safety Compliance is responsible for how the Effective Projected Luminous Lens Area mandates will be enforced.

Bottom line – anyone with a basic Technical Background, studying the official definitions of “effective light emitting surfaces” and “effective projected luminous lens area”, will find that nearly all of the Aftermarket LED Brake and Turn Signals now being supplied to OEM Trailer Manufacturers are indeed, illegal, thereby making all involved subject to Recalls.  Further, those supplying Non-Compliant Lighting that’s involved in any Rear End, Turning or Lane Changing Crash
can be partially or wholly blamed and held Liable for some - or all - of the resulting damages and injuries.

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