NHTSA Proposes Modernizing FMVSS No. 108 for ADS Equipped Vehicles
On October 26, 2026, NHTSA proposed amendments to FMVSS No. 108 for lamps, reflective devices and associated equipment. The proposal would update integral-beam headlamp test voltage, provide flexibility for upper and lower beam mounting, and limit requirements for manual turn-signal, hazard-warning, beam-switching controls and telltales when an ADS-equipped vehicle has no manually operated driving controls.
It would also permit optional cyan ADS marker lamps with standardized performance. Comments are due November 25, 2026, and the proposal is not yet a final rule.
Impact
Impact assessment: Medium.
Key reasons: The proposal could materially change lighting design and test evidence for ADS-equipped vehicles, but it remains an NPRM and does not yet modify the binding standard.
Who is affected?
Vehicle manufacturers, ADS developers, lighting and control suppliers, test laboratories, compliance engineers, importers and vehicle certification teams.
Conclusion:
Map affected vehicle programs and lighting functions to the proposed clauses, evaluate cyan marker-lamp and control implications, and submit technical comments by November 25, 2026. Continue applying the current FMVSS No. 108 until a final rule is issued.
Regulatory Authority
National Highway Traffic Safety Administration (NHTSA), U.S. Department of Transportation
Regulatory Impact
| Impact Type | Status |
|---|---|
| Top Priority | |
| Type Certificate | |
| Spectrum Bands | |
| Import Changes (HS Codes) | |
| Standard Changes | |
| Product Changes | |
| Label Changes |
United States of America Quick Facts
| Regulatory Agency | Federal Communications Commission (FCC) |
| Certification Type | Mandatory for most telecom equipment |
| License Validity | Valid indefinitely as long as compliance is maintained |
| Application Language | English |
| Legal License Holder | Local representative may be required for some cases |
| In-country Testing Requirement | May be required for certain telecom equipment |
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