Introduction
Ford Motor Company has determined that front turn signal lamps on approximately 14,967 model year 2020-2025 Ford Transit vehicles fail to meet a key requirement under Federal Motor Vehicle Safety Standard No. 108. The company filed a noncompliance report on October 25, 2024, and followed with a petition on November 15, 2024, asking the National Highway Traffic Safety Administration to deem the issue inconsequential to motor vehicle safety. This development highlights ongoing tensions between regulatory compliance and practical safety assessments in the automotive industry. At stake is whether Ford must notify owners and remedy the vehicles, as mandated by federal law, or if the agency will grant an exemption based on Ford's arguments that the shortfall has no meaningful impact on road safety.
The noncompliance affects Transit vehicles with an overall width of 80 inches or more, equipped with High Intensity Discharge headlamps. These include all dual rear wheel models, Transit Trail Adventure Vans, and certain single rear wheel cutaways and chassis-cab variants fitted with upfitter boxes meeting the width threshold. Manufactured between May 1, 2019, and October 10, 2024, at Ford's Kansas City Assembly Plant, the vehicles feature turn signals with an effective projected luminous lens area of 6313 square millimeters, below the 7500 square millimeters required for such wide vehicles. NHTSA's notice, published in the Federal Register on December 16, 2025, announces receipt of the petition and opens a public comment period until January 15, 2026.
Background on FMVSS No. 108 and the Noncompliance
Federal Motor Vehicle Safety Standard No. 108 governs lamps, reflective devices, and associated equipment on motor vehicles to ensure visibility and signaling effectiveness. Paragraph S7.1.1.6 of the standard references Table IV-a, which specifies a minimum effective projected luminous lens area, or EPLLA, of 7500 square millimeters for front turn signal lamps on multipurpose passenger vehicles, trucks, trailers, and buses that are 2032 millimeters - equivalent to 80 inches - or wider. EPLLA measures the visible illuminated area of a lamp when viewed from the front, ensuring signals are conspicuous to other road users.
Ford identified the issue through an internal review by its Critical Concern Review Group on September 5, 2024. The company issued a stop-ship order at the Kansas City plant on September 15, 2024, halting distribution of affected vehicles. By October 13, 2024, Ford reported no warranty claims, field reports, customer complaints, or vehicle owner questionnaires related to the turn signals. Production of compliant vehicles with HID headlamps resumed on November 18, 2024, featuring turn signals exceeding the 7500 square millimeter threshold. Notably, Transit models with halogen headlamps are unaffected, as their turn signals meet the standard with an EPLLA of 7530 square millimeters.
Ford's Arguments for Inconsequentiality
Ford contends that the noncompliance poses no safety risk, emphasizing that the turn signals' performance remains effective despite the technical shortfall. The company urges evaluation from the perspective of pedestrians and other drivers, arguing that the difference is imperceptible in real-world conditions.
A key element of Ford's petition is a jury evaluation conducted to assess visibility. In this study, 25 participants compared compliant and noncompliant turn signals on two Transit vehicles under simulated daytime and nighttime conditions. One vehicle had a compliant signal on the right and noncompliant on the left with clean lenses, while the other reversed the setup with dirt-covered lenses. Observers viewed from various distances, including standing and seated positions to mimic pedestrians and drivers. Results showed no significant perceived difference in size or conspicuity, with parking lamps activated during nighttime tests as required.
Ford also performed a computer-aided engineering airflow study comparing dirt and grime accumulation on headlamps of vehicles under and over 80 inches wide. The analysis found no difference in airflow velocity profiles, suggesting wider vehicles are not more prone to lens obscuration that could exacerbate the EPLLA shortfall.
Additionally, Ford cites the use of identical turn signals on European Transit models, which comply with Economic Commission for Europe standards, though it acknowledges the lack of a direct EPLLA equivalent. The company reports no complaints, accidents, or injuries linked to the issue in its records.
Relevant Precedents and Perspectives
Ford references several NHTSA decisions granting inconsequentiality for similar minor deviations where testing showed no perceptible safety impact. For instance, in 2014, the agency granted Harley-Davidson Motor Company's petition for reflex reflectors mounted 0.3 to 0.7 inches below the required height, citing imperceptibility. Similar grants occurred for Porsche in 2020 (0.2-inch shortfall) and General Motors in 1998 (photometric failures in stop lamps). Osram Sylvania's 2013 petition for noncompliant light sources was also approved based on minimal differences.
Ford distinguishes its case from a 2024 denial for Winnebago, where noncompliant turn signals with 6361 square millimeters EPLLA were deemed consequential. Ford highlights its jury and airflow studies, absent in Winnebago's petition, and design differences like vehicle aerodynamics that reduce dirt buildup on Transits.
Stakeholders may view this differently. Safety advocates could argue that any deviation from standards risks cumulative effects on visibility, especially in adverse conditions. Regulators might weigh Ford's evidence against the standard's intent to ensure robust signaling for wide vehicles, which often operate in commercial or high-traffic environments. Manufacturers, however, may see this as an opportunity to challenge overly rigid requirements when data shows no harm.
Potential Implications
If granted, Ford's petition would exempt the company from recall obligations under 49 U.S.C. 30118 and 30120, potentially setting a precedent for evaluating EPLLA noncompliance through perceptual testing. Short-term, this could streamline compliance for minor technical issues, reducing costs for manufacturers. Long-term, it might influence how NHTSA assesses visibility standards amid evolving vehicle designs, such as larger commercial vans.
Conversely, denial could reinforce strict adherence, prompting broader industry reviews of lamp compliance. For affected owners, the outcome determines whether notifications and remedies are required, though Ford's lack of reported incidents suggests low immediate risk.
In summary, this petition underscores the balance between regulatory precision and practical safety. NHTSA will consider public comments before deciding, with a notice of the outcome to follow in the Federal Register.
