Notice2025-22847
Ford Motor Company, Receipt of Petition for Decision of Inconsequential Noncompliance
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
December 16, 2025
Issuing agencies
Transportation DepartmentNational Highway Traffic Safety Administration
Abstract
Ford Motor Company (Ford) has determined that certain model year (MY) 2020-2025 Ford Transit motor vehicles do not fully comply with Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices, and Associated Equipment. Ford filed a noncompliance report dated October 25, 2024, and subsequently petitioned NHTSA (the "Agency") on November 15, 2024, for a decision that the subject noncompliance is inconsequential as it relates to motor vehicle safety. This document announces receipt of Ford's petition.
Full Text
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<title>Federal Register, Volume 90 Issue 239 (Tuesday, December 16, 2025)</title>
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[Federal Register Volume 90, Number 239 (Tuesday, December 16, 2025)]
[Notices]
[Pages 58368-58370]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-22847]
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DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety Administration
[Docket No. NHTSA-2024-0097; Notice 1]
Ford Motor Company, Receipt of Petition for Decision of
Inconsequential Noncompliance
AGENCY: National Highway Traffic Safety Administration (NHTSA),
Department of Transportation (DOT).
ACTION: Receipt of petition.
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SUMMARY: Ford Motor Company (Ford) has determined that certain model
year (MY) 2020-2025 Ford Transit motor vehicles do not fully comply
with Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps,
Reflective Devices, and Associated Equipment. Ford filed a
noncompliance report dated October 25, 2024, and subsequently
petitioned NHTSA (the ``Agency'') on November 15, 2024, for a decision
that the subject noncompliance is inconsequential as it relates to
motor vehicle safety. This document announces receipt of Ford's
petition.
DATES: Send comments on or before January 15, 2026.
ADDRESSES: Interested persons are invited to submit written data,
views, and arguments on this petition. Comments must refer to the
docket and notice number cited in the title of this notice and may be
submitted by any of the following methods:
<bullet> Mail: Send comments by mail addressed to the U.S.
Department of Transportation, Docket Operations, M-30, West Building
Ground Floor, Room W12-140, 1200 New Jersey Avenue SE, Washington, DC
20590.
<bullet> Hand Delivery: Deliver comments by hand to the U.S.
Department of Transportation, Docket Operations, M-30, West Building
Ground Floor, Room W12-140, 1200 New Jersey Avenue SE, Washington, DC
20590. The Docket Section is open on weekdays from 10 a.m. to 5 p.m.
except for Federal Holidays.
<bullet> Electronically: Submit comments electronically by logging
onto the Federal Docket Management System (FDMS) website at <a href="https://www.regulations.gov/">https://www.regulations.gov/</a>. Follow the online instructions for submitting
comments.
<bullet> Comments may also be faxed to (202) 493-2251.
Comments must be written in the English language, and be no greater
than 15 pages in length, although there is no limit to the length of
necessary attachments to the comments. If comments are submitted in
hard copy form, please ensure that two copies are provided. If you wish
to receive confirmation that comments you have submitted by mail were
received, please enclose a stamped, self-addressed postcard with the
comments. Note that all comments received will be posted without change
to <a href="https://www.regulations.gov">https://www.regulations.gov</a>, including any personal information
provided.
All comments and supporting materials received before the close of
business on the closing date indicated above will be filed in the
docket and will be considered. All comments and supporting materials
received after the closing date will also be filed and will be
considered to the fullest extent possible.
When the petition is granted or denied, notice of the decision will
also be published in the Federal Register pursuant to the authority
indicated at the end of this notice.
All comments, background documentation, and supporting materials
submitted to the docket may be viewed by anyone at the address and
times given above. The documents may also be viewed on the internet at
<a href="https://www.regulations.gov">https://www.regulations.gov</a> by following the online instructions for
accessing the dockets. The docket ID number for this petition is shown
in the heading of this notice.
DOT's complete Privacy Act Statement is available for review in a
Federal Register notice published on April 11, 2000 (65 FR 19477-78).
FOR FURTHER INFORMATION CONTACT: Kelley Adams-Campos, Safety Compliance
Engineer, NHTSA, Office of Vehicle Safety Compliance, (202) 366-7479.
SUPPLEMENTARY INFORMATION:
I. Overview: Ford determined that certain MY 2020-2025 Ford Transit
motor vehicles do not fully comply with paragraph S7.1.1.6 and Table
IV-a of FMVSS No. 108, Lamps, Reflective Devices, and Associated
Equipment. (49 CFR 571.108).
Ford filed a noncompliance report dated October 25, 2024, pursuant
to 49 CFR part 573, Defect and Noncompliance Responsibility and
Reports. Ford petitioned NHTSA on November 15, 2024, for an exemption
from the notification and remedy requirements of 49 U.S.C. Chapter 301
on the basis that this noncompliance is inconsequential as it relates
to motor vehicle safety, pursuant to 49 U.S.C. 30118(d) and 30120(h)
and 49 CFR part 556, Exemption for Inconsequential Defect or
Noncompliance.
This notice of receipt of Ford's petition is published under 49
U.S.C. 30118 and 30120 and does not represent any agency decision or
another exercise of judgment concerning the merits of the petition.
II. Vehicles Involved: Approximately 14,967 MY 2020-2025 Ford
Transit motor vehicles, manufactured between May 1, 2019, to October
10, 2024, were reported by the manufacturer. Ford notes that the
noncompliance affects the Transit vehicles with an overall width
greater than or equal to 80 inches,\1\ built at the Kansas City
Assembly Plant, equipped with High Intensity Discharge (HID) headlamps.
This includes all Dual Rear Wheel vehicles, Transit Trail Adventure
Vans, and Single Rear Wheel Cutaways and Chassis-Cab vehicles fitted
with an upfitter box that is at least 80 inches wide.
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\1\ This receipt notice uses ``80 inches'' and ``2032 mm''
interchangeably.
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III. Rule Requirements: Paragraph S7.1.1.6 of FMVSS No. 108
includes the requirements relevant to this petition. Paragraph S7.1.1.6
references Table IV-a which provides the required minimum effective
projected luminous lens area (EPLLA) values for front turn signal
lamps. Specifically, the required EPLLA minimum value for front turn
signal lamps on multipurpose passenger vehicles, trucks, trailers, and
buses 2032 mm or more in overall width is 7500 sq mm.
IV. Noncompliance: Ford explains that the front turn signal lamps
installed on the subject vehicles have an EPLLA of 6313 sq mm, which is
less than the
[[Page 58369]]
minimum 7500 sq mm required for vehicles with an overall width of 2032
mm or more.
V. Summary of Ford's Petition: The following views and arguments
presented in this section, ``V. Summary of Ford's Petition,'' are the
views and arguments provided by Ford. They have not been evaluated by
the Agency and do not reflect the views of the Agency. Ford describes
the subject noncompliance and contends that the noncompliance is
inconsequential as it relates to motor vehicle safety.
On September 5, 2024, Ford's Critical Concern Review Group (CCRG)
determined, after review, that certain Ford Transit vehicles built at
its Kansas City Assembly Plant (KCAP) were equipped with front turn
signal lamps that did not meet the minimum EPLLA required by paragraph
S7.1.1.6 and Table IV-a of FMVSS No. 108. Ford clarifies that the
subject noncompliance does not affect Ford Transit vehicles fitted with
halogen headlamps which have front turn signal lamps with an EPLLA of
7530 sq mm. Ford notes that on September 15, 2024, a stop-ship was
issued at KCAP and that, as of October 13, 2024, there are no warranty
claims, field reports, customer complaints or Vehicle Owner Questioners
(VOQs) regarding the subject noncompliance. Ford also states that on
November 18, 2024, KCAP ``started to build'' \2\ Transit vehicles with
compliant HID headlamps with front turn signal EPLLA that exceeds 7500
sq mm.
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\2\ Ford's petition is dated November 15, 2024.
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Ford argues that ``in order to make a determination that the
noncompliance is inconsequential to safety, one should evaluate it from
the viewpoint of a pedestrian or other drivers.'' Ford approaches its
analysis from this viewpoint and gives five reasons why the subject
noncompliance is inconsequential to motor vehicle safety:
1. Ford states that there is no perceptible difference between the
illuminated area of a noncompliant Transit HID front turn signal lamp
and a compliant front turn signal lamp.
Ford states that results from a jury evaluation it conducted
demonstrate that there is no reasonably perceptible difference in the
illuminated area of a compliant versus noncompliant Transit HID
headlamp front turn signal. Ford explains that, for the jury
evaluation, two Transit vehicles were set up as follows: One having the
right-hand headlamp (A) with a ``compliant'' turn signal (EPLLA greater
than 7500 sq mm) and the left-hand headlamp (B) with the subject
noncompliant turn signal (EPLLA of 6313 sq mm), each with clean
headlamp lens surfaces. The other vehicle was set up having the right-
hand headlamp (C) with the subject noncompliant turn signal (EPLLA of
6313 sq mm) and the left-hand headlamp (D) with a ``compliant'' turn
signal (EPLLA greater than 7500 sq mm), with both headlamp lens
surfaces covered with dirt. According to Ford, twenty-five (25) jurors
were positioned directly in front of the turn signal under observation,
from varied standing distances and one seated distance, (to simulate
pedestrian and driver). Ford states that observations were made in
simulated daytime and nighttime conditions, with the parking lamps
illuminated during the nighttime evaluation ``as it is required that
parking lights be activated during nighttime conditions.'' Ford
explains that the ``[L]eft-hand and right-hand headlamps were observed
in quick succession'' and that the jurors did not know which front turn
signal had the larger or smaller EPLLA. The jurors were asked to
determine if they could identify which front turn signal lamps were
larger or more noticeable on each vehicle. Ford states the results of
its jury evaluation show that, for both vehicle set-ups, jurors found
no significant size or conspicuity difference between compliant and
noncompliant front turn signal lamps.\3\
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\3\ See Appendix A of Ford's petition for the jury evaluation
set up, juror questionnaire, viewing positions and jury evaluation
results.
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2. Ford contends that the nominal differences in overall width of
the subject vehicles does not affect the amount of dirt and grime
buildup on the headlamps.
Ford states that it conducted a Computer Aided Engineering airflow
study to compare the airflow velocity profile around the headlamp of a
Transit vehicle less than 80 inches in overall width with one greater
than 80 inches wide.\4\ Ford concludes that the overall width of
Transit vehicles does not affect the amount of dirt and grime buildup
on the headlamp and Transit vehicles with a width greater than 80
inches, that have noncompliant front turn signals, would not be at
greater risk due to dirt and grime buildup.
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\4\ See Appendix B of Ford's petition for an overlay of the
airflow velocity profiles around the headlamps.
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3. Ford says that NHTSA has granted similar petitions in the past
where the manufacturer conducted testing and analysis to demonstrate
that the noncompliance would be imperceptible.
Ford believes that the following inconsequential noncompliance
petitions granted by NHTSA support the granting of the current
petition:
<bullet> Harley-Davidson Motor Company, Inc., Grant of Petition for
Decision of Inconsequential Noncompliance; 79 FR 69558 (Nov. 21, 2014).
The noncompliance in Harley-Davidson's petition concerned rear reflex
reflectors mounted an average of 0.3 inches to 0.7 inches below the
required 15 inches above the road surface of FMVSS No. 108.
<bullet> Porsche Cars North America, Inc., Grant of Petition for
Decision of Inconsequential Noncompliance; 85 FR 62365 (Oct. 2, 2020).
The noncompliance in Porsche's petition concerned rear reflex
reflectors mounted approximately 0.2 inches below the required 15
inches above the road surface of FMVSS No. 108.
<bullet> General Motors Corporation; Grant of Application for
Decision of Inconsequential Noncompliance; 63 FR 70179 (December 18,
1998). The noncompliance in GM's petition concerned the center high-
mounted stop lamp that failed to meet the minimum photometric
requirements of FMVSS No. 108.
<bullet> Osram Sylvania Products Incorporated, Grant of Petition
for Decision of Inconsequential Noncompliance; (78 FR 46000) July 30,
2013. The noncompliance in Osram's petition concerned Type HB2
replaceable light sources failing to meet the required dimensions and
electrical specifications pursuant to 571.564 as referenced by FMVSS
No. 108 S7.7.\5\
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\5\ Paragraph S7.7 of FMVSS No. 108 was replaced by paragraph
S11 on December 4, 2007, w/effective date December 1, 2012 (72 FR
68234).
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Ford adds that the subject noncompliance is distinct from an
inconsequentiality petition by Winnebago (89 FR 77581) that was denied
by NHTSA on September 23, 2024. The Winnebago petition concerned
noncompliant front turn signal lamps with an EPLLA under the minimum
specified in FMVSS No. 108.\6\ Ford gives several reasons why its
petition is distinct from the Winnebago petition:
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\6\ According to Winnebago's petition, the noncompliant front
turn signal EPLLA was 6361 sq mm.
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<bullet> Ford conducted a jury evaluation and analysis, to show
that the difference in area is not perceptible between compliant and
noncompliant front turn signal lamps.
<bullet> Ford conducted a CAE airflow study, to verify that there
is not a greater masking effect of dirt and grime buildup on the
noncompliant vehicles compared to compliant vehicles.
<bullet> Design differences between the Ford Transit vehicles and
the
[[Page 58370]]
Winnebago motorhomes \7\ that Ford contends are important in reducing
the propensity that dirt and grime will accumulate on the headlamps in
Ford Transit vehicles. Ford explains that these differences include
vehicle size, shape, width, front turn signal mounting layout, and
aerodynamics. See Appendix C of Ford's petition.
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\7\ Ford cites <a href="https://www.winnebago.com/brochure?model=">https://www.winnebago.com/brochure?model=</a>
(accessed Nov. 12, 2024).
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4. The same front turn signals are used on Transit vehicles sold in
Europe and meet all ECE requirements.
Ford states that it sells Transit vehicles in North America and
Europe and that the same front turn signal lamps are used in the HID
variants in both markets. Ford states that it measured the illuminating
surface of the front turn signal lamp following the ECE methodology and
found it to be greater than 7500 sq mm. Ford states it recognizes there
is not an equivalent ECE requirement for EPLLA.
5. There are no known complaints, accidents or injuries related to
this noncompliance.
Ford states that it searched its records and found no complaints,
accidents, or reported injuries related to the noncompliant headlamps.
Ford goes on to say that it ``believes that the lack of complaints,
accidents, or injuries is further evidence that this non-compliance is
inconsequential and that non-compliant front turn signals are not
perceptible in the field.''
Ford concludes by stating its belief that the subject noncompliance
is inconsequential as it relates to motor vehicle safety and its
petition to be exempted from providing notification of the
noncompliance, as required by 49 U.S.C. 30118, and a remedy for the
noncompliance, as required by 49 U.S.C. 30120, should be granted.
NHTSA notes that the statutory provisions (49 U.S.C. 30118(d) and
30120(h)) that permit manufacturers to file petitions for a
determination of inconsequentiality allow NHTSA to exempt manufacturers
only from the duties found in sections 30118 and 30120, respectively,
to notify owners, purchasers, and dealers of a defect or noncompliance
and to remedy the defect or noncompliance. Therefore, any decision on
this petition only applies to the subject vehicles that Ford no longer
controlled at the time it determined that the noncompliance existed.
However, any decision on this petition does not relieve vehicle
distributors and dealers of the prohibitions on the sale, offer for
sale, or introduction or delivery for introduction into interstate
commerce of the noncompliant vehicles under their control after Ford
notified them that the subject noncompliance existed.
(Authority: 49 U.S.C. 30118, 30120: delegations of authority at 49
CFR 1.95 and 501.8)
Otto G. Matheke III,
Director, Office of Vehicle Safety Compliance.
[FR Doc. 2025-22847 Filed 12-15-25; 8:45 am]
BILLING CODE 4910-59-P
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</html>Indexed from Federal Register on December 16, 2025.
This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.