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**NORTH AMERICAN LIGHTING, Inc.**

**[38900 Hills Tech Dr. / Farmington Hills, MI 48331 / Phone:
248/553-6408 / Fax: 248/553-6454]{.smallcaps}**

# July 21, 2008

> Docket Management Facility
>
> U.S. department of Transportation
>
> 1200 New Jersey Avenue, SE.
>
> West Building Ground Floor, Room W12-140
>
> Washington D. C. 20590-0001

## Re: North American Lighting Inc. Comments on

## Guidance and Recommended Best Importer Practices To Enhance the Safety of Motor Vehicles and Motor Vehicle Equipment

### Docket No. NHTSA 2008-0113; Notice 1

> North American Lighting thanks you for the opportunity to comment on
> the Best Importer Practices To Enhance the Safety of Motor Vehicles
> and Motor Vehicle Equipment, since this is an area that directly
> effects the automotive lighting industry.
>
> North American Lighting is a designer and manufacturer of exterior
> automotive lighting products with a diversified customer base not only
> in the United States but world wide. With our parent company, Koito
> Manufacturing, and our sister companies through out Europe and Asia,
> we are one of the largest suppliers of exterior lighting products in
> the world. We work hard and spare no expense to meet and exceed the
> requirements of the countries our lighting products are used in. This
> is why we support the efforts of the US Department of Transportation
> in designing a set of Best Importer Practices to ensure the quality of
> imported lighting products brought into the United States. These
> lighting products are considered safety items and therefore have rules
> and regulations that must be followed in their manufacture and
> compliance testing that must be fulfilled. North American Lighting has
> a responsibility to our customers to meet the lighting regulations of
> the countries our customers sell their vehicles. This responsibility
> includes the aftermarket or replacement markets, as well. The OEM and
> aftermarket products are both subject to the same regulations and
> compliance testing. We feel this should hold true for all suppliers
> sending lamps into the United States for either OEM sale or
> aftermarket sale. The vehicle manufacturer is legally responsible for
> the vehicles brought to market and all the components on them. The
> importers for these aftermarket suppliers should be responsible for
> the products imported for sale in this country. Why should importers
> not have to prove they can meet the necessary requirements for their
> products? This would be similar to what U.S. suppliers have to do when
> we build products for the European markets or the Chinese markets. In
> most cases we have to perform witness testing and show process checks.
> In some cases we have to allow our plants to be inspected by
> government officials and ship product to outside test houses, in order
> to be allowed to ship product into foreign countries.
>
> Without similar controls by the U.S., these overseas suppliers can
> send just about anything into this country and no one is accountable.
> If you are importing lighting products into this country for sale,
> aftermarket or OEM, then the importer should hold the same liability
> as the vehicle manufacturer, for what he sells. Today, an importer can
> take a U.S. lamp overseas, have it manufactured, import it, and sell
> it for less money, at a larger profit, and not have any responsibility
> for the quality or safety. The automotive lighting importer should be
> responsible for what is sold in the US. All lighting suppliers should
> equally be required to have proof that the manufacturing plants have
> passed inspection, and that the products being imported can pass all
> required testing, not just that it has a "DOT" on it.
>
> Thank you again for this opportunity to comment.
>
> Sincerely,
>
> Gary L. King
>
> Manager of Regulations & Standards
>
> North American Lighting, Inc.
>
> 38900 Hills Tech Drive
>
> Farmington Hills, MI 48331-3430
>
> 248-522-2155 direct, fax: 248-553-6454, or 6591
>
> gking@nal.