Tesla asked U.S. safety regulators to rewrite federal headlight rules so they account for camera-controlled, software-updated matrix LED lamps, and to give automakers more seats on a proposed advisory committee, according to a Nov. 9 letter described by Tesla North and The Electric Standard.
Why it matters: The National Highway Traffic Safety Administration is considering a negotiated rulemaking to modernize Federal Motor Vehicle Safety Standard No. 108, which covers lamps and related equipment. The letter is a comment on that plan, not a new adopted rule.
The Electric Standard said the letter, signed by Suraj Nagaraj, Tesla’s senior director of safety and homologation engineering, was filed Nov. 9 in docket NHTSA-2026-1981, the deadline NHTSA set after an Oct. 8 Federal Register notice. Tesla argued that FMVSS 108 “was written for an era in which a headlamp was a replaceable bulb in a housing,” and that glare, beam photometry, aim, mounting height and adaptive-beam performance “cannot be resolved by lamp-level laboratory points alone,” both outlets quoted. The company said its matrix lamps have individually addressable segments whose behavior can be refined over the air within a certified envelope, using the same surround cameras that detect other vehicles, pedestrians, cyclists and road geometry.
Tesla also objected to reserving only two of as many as 18 committee seats for individual automakers, compared with four for lighting manufacturers or retailers, and asked for more automaker representation. NHTSA has said any consensus recommendations would later go into a proposed rule for public comment. Tesla North noted that adaptive headlights are already available on compatible U.S. and Canadian Teslas through software update 2025.14; this filing concerns future standards, not a newly announced feature rollout.