Dr. Niall R. Lynam

Senior Vice President

Magna Mirrors of America, Inc.

49 West 3rd Street

Holland, Michigan 49423


Dear Dr. Lynam:


This responds to your letter, dated March 5, 2013, requesting clarification on Federal Motor Vehicle Safety Standard (FMVSS) No. 111, Rearview Mirrors, as it pertains to the driver’s side outside rearview mirror of a passenger car.


Your letter asks whether FMVSS No. 111 permits the use of a “convex mirror having a radius of curvature of thirty (30) meters and a magnification of 0.95 as the driver’s side outside rearview mirror on a passenger car.”  Your letter also requests that, for purposes of providing an interpretation, NHTSA assume that that the mirror’s field of view is in accordance with S5.2.1, the mounting is in accordance with S5.2.2, and the construction is in accordance with S11.


Even if we make the assumptions that you request, the plain language of FMVSS No. 111 does not allow convex mirrors as driver’s side outside rearview mirrors.  FMVSS No. 111 defines two types of mirrors, convex mirrors and mirrors of unit magnification.  Paragraph S.4 defines a convex mirror as “having a curved reflective surface,” whereas a unit magnification mirror is defined as “a plane or flat mirror.”  Paragraph S5.2 of the standard, Outside rearview mirror—driver's side, applies specifically to the driver’s side rearview mirror.  It states, in relevant part, that [e]ach passenger car shall have an outside mirror of unit magnification.”  Thus, it does not permit the use of the “convex” mirror described in your letter, regardless of its radius of curvature.  Rather, a mirror that is flat or plane must be used as the driver’s side mirror in order to comply with the standard.


I hope this information is helpful.  If you have further questions, please contact Jesse Chang of my staff at 202-366-2992.






O. Kevin Vincent

Chief Counsel

Dated: 8/15/13