Tesla has asked the National Highway Traffic Safety Administration to give carmakers more seats on a proposed committee to modernize FMVSS No. 108, the federal vehicle lighting standard, in a comment letter dated 9 November. The letter says the standard “was written for an era in which a headlamp was a replaceable bulb in a housing, switched between two static beam patterns by the driver or a simple photocell”.
NHTSA’s notice of 8 October proposes a committee of up to 18 members, two of them from national motor vehicle manufacturers. That is 11% of the seats, by our arithmetic. The docket showed 5,722 public comments posted when we checked regulations.gov at 09:43 UTC on 11 November.
Business Pill · Physical AI
An evergreen Business Engineer explainer on physical AI: when software that perceives the world gets a body. It teaches the general idea only and does not discuss Tesla’s letter.
The key insight: As we read it, Tesla’s letter turns a seat count into an argument about where lighting is engineered: if beam switching is a camera-and-software problem, as the letter says, then the carmaker rather than the lamp supplier owns the behavior, and NHTSA’s draft gives carmakers 2 of 18 seats, 11% by our arithmetic.
The letter, signed by Suraj Nagaraj, Senior Director, Safety and Homologation Engineering, says Tesla “designs and integrates exterior lighting as part of a software-defined vehicle”. It says its matrix LED headlamps have individually addressable segments controlled in real time by vehicle software, and that the lighting control system “can be refined over the air, within the certified performance envelope”.
It adds: “Tesla does not treat lighting as an isolated supplier module whose only โsensorโ is a dusk photocell”. Lighting behavior, the letter says, is informed by the same surround-camera suite that observes oncoming headlamps, preceding taillamps, pedestrians, cyclists, lane geometry and ambient illumination.
From that, Tesla argues that “Semiautomatic beam switching and adaptive driving beam functions are therefore scene-understanding problems, not binary light-threshold problems”. It says glare, beam photometry, aim and mounting height, and adaptive-beam performance “cannot be resolved by lamp-level laboratory points alone”.
Proposed members of NHTSA’s Negotiated Rulemaking Advisory Committee for Vehicle Lighting, by group, from the agency’s notice of 8 October 2026. Vehicle manufacturers would hold 2 of up to 18 seats; Tesla’s 9 November letter asks for more.
What Was Posted on X
Tesla has submitted a new letter to NHTSA, urging the federal government to modernize U.S. vehicle lighting regulations.
Tesla argues that existing regulations were designed for traditional headlights, not modern matrix LED systems that use vehicle cameras to detect other vehicles, pedestrians, and cyclists and dynamically adjust light beams to improve visibility and reduce glare.
Tesla also wants regulations to account for lighting improvements delivered through over-the-air software updates and is pushing for automakers to have greater representation in shaping the new rules.
Tesla: “We do not treat lighting as an isolated supplier module whose only โsensorโ is a dusk photocell. Lighting behavior is informed by the same surround-camera suite that continuously observes the driving scene: oncoming headlamps, preceding taillamps, pedestrians, cyclists, lane geometry, and ambient illumination. Semiautomatic beam switching and adaptive driving beam functions are therefore scene understanding problems, not binary light-threshold problems.
Tesla has concerns about NHTSAโs proposed composition of the advisory committee tasked with reaching consensus recommendations. Specifically, Tesla urges the agency to increase the number of individual vehicle manufacturer committee members from the current proposal of just two representatives. The current proposal does not accurately reflect the interests of individual motor vehicle manufacturers, particularly when those interests will not be represented by a trade or industry association member of the committee.”
Sawyer Merritt flagged the letter on X at 14:43 UTC on 10 November and summarised it: modern matrix LED headlamps that use vehicle cameras, lighting improvements delivered over the air, and more automaker representation in shaping the new rules. He quoted two passages, which we checked against the letter on regulations.gov; this piece quotes the letter itself.
The Seat Count
The NHTSA notice proposes four representatives from vehicle lighting manufacturers or lighting retailers, two from national motor vehicle manufacturers and four from national motor vehicle or equipment manufacturing associations. It adds two from safety organizations, three from educational, research or testing bodies, and three from engineering or standard-setting associations. A NHTSA representative would also sit on the committee.
Tesla’s letter says “The proposed advisory committee skews heavily in favor of vehicle lighting manufacturers and lighting retailers and related trade associations to the detriment of motor vehicle manufacturers”. It asks NHTSA to expand individual vehicle manufacturer members “to at least the same proportion as members from vehicle lighting manufacturers and lighting retailers, and national motor vehicle or motor vehicle equipment manufacturing associations”.
The letter cites the statute that limits a negotiated rulemaking committee to 25 members unless more are needed to achieve balanced membership, and says NHTSA’s proposal limits the committee to 18. NHTSA’s notice says that “no single group would have a controlling stake in the committee”.
What NHTSA Put on the Table
The notice lists the topics: glare caused by headlighting systems, replaceable light sources, dusk sensors, semiautomatic beam switching, lower and upper beam photometry, on-vehicle headlamp performance that considers aim and mounting height, and harmonization to international standards, among others. It says NHTSA began the rulemaking action (RIN 2127-AL95) in the Spring 2018 Unified Agenda.
The committee would work under a two-year charter, meet approximately four times per year, and produce a term sheet of consensus recommendations to inform a proposed rule, the notice says. Tesla’s letter notes that NHTSA’s prior negotiated rulemaking for FMVSS 108, in 1995, was limited to a single issue: lower beam headlamp patterns. For Tesla’s robotaxi push in Texas, see our piece on Tesla’s Texas robotaxi list.
NHTSA’s proposed committee of up to 18 members, 2 of them from vehicle manufacturers, against the 25-member limit in 5 U.S.C. 565(b) cited in Tesla’s letter. The 16 other seats and 7 seats below the limit are our arithmetic.
Our Numbers
Lighting makers and retailers plus the manufacturing associations would hold 8 of the 18 proposed seats, or 44%, against 2 seats for carmakers, by our arithmetic. The proposed 18 members leave 7 seats below the statutory limit of 25 that Tesla cites.
Of the 5,722 comments posted on the docket, 2,579 were posted from 9 to 11 November, according to the regulations.gov count we read. It has been 31 years since the 1995 negotiated rulemaking that Tesla’s letter cites, by our arithmetic.
The Structural Read
As we read the letter, the over-the-air point is the business lever: Tesla says its lighting control system can be refined over the air within the certified performance envelope, so a standard written around fixed lamp photometry would govern a feature Tesla ships as software.
As we read the notice, NHTSA has framed the committee as a balance of supplier, carmaker, safety, research and standards voices, and says no single group would have a controlling stake; Tesla’s letter argues that the balance tilts toward lighting suppliers and trade associations.
Suraj Nagaraj, Senior Director, Safety and Homologation Engineering, Tesla, letter to NHTSA, 9 November 2026
“Motor vehicle manufacturers are responsible for lighting performance and the safety of vehicles operated on U.S. roads, yet are one of the groups least represented in the composition of the proposed advisory committee”
Three Implications
FOR CARMAKERSTesla’s letter says the interests of individual vehicle manufacturers will not be adequately represented by two representatives, and asks for a broader bench.
FOR LIGHTING SUPPLIERS The NHTSA notice proposes four seats for vehicle lighting manufacturers or lighting retailers, the joint-largest group with the manufacturing associations.
FOR THE RULE ITSELF The notice says the committee would produce a term sheet of consensus recommendations to inform a NHTSA rulemaking proposal under a two-year charter.
The framework argues: “In any product cycle, there are two curves to follow.” One is what the technology can do; the other is what users can actually do with it.
As we read it, Tesla’s letter describes a regulatory version of that gap: headlamps that the letter says are steered by cameras and updated over the air, under a standard it says was written for bulbs and photocells. The framework predates the letter and does not discuss it.
What Is Not Established
Tesla’s letter does not give a number of seats it wants for carmakers; it asks for at least the same proportion as the supplier and association groups. The documents we read do not include a NHTSA response to the letter, and the notice says NHTSA will consider the comments received in establishing the committee.
The letter gives no count of Tesla vehicles with matrix LED headlamps and no timeline for a final rule. For how NHTSA has handled another automated-driving file, see our piece on its Waymo school-bus recall query.
This Week In The AI Supercycle
The Great Convergence of Capital, Power, and Geopolitics
This week’s issue: for two years the AI build-out was priced as a supply story, and last week as a credit story. This week it was priced as a permission story, and the answer arrived as a cost, not a ban.
Tesla backs NHTSA’s plan to rewrite the lighting standard through a negotiated rulemaking, but says the proposed 18-member committee gives carmakers 2 seats while lighting suppliers and trade associations hold more. Its letter argues that camera-informed, software-updated headlamps make lighting a system-level question rather than a lamp-level one.
A note on sourcing. We read Tesla’s comment letter of 9 November 2026 on regulations.gov (Docket NHTSA-2026-1981) and NHTSA’s notice of 8 October 2026 in the Federal Register in full. The comment counts come from the regulations.gov docket at 09:43 UTC on 11 November. Shares and differences are our arithmetic. Neither Tesla nor NHTSA was contacted for this piece; the letter was flagged on X by Sawyer Merritt.
Gennaro Cuofano is a CRO and tech executive who has worked in AI since late 2015, starting with bringing NLP, natural-language generation, voice and chatbot products to the marketing industry. His background is in law and finance: he holds a Master's degree in Law and an International MBA with an emphasis on corporate finance (LUISS Business School and the University of San Diego, 2012), and worked as a financial analyst at a real-estate investment firm in San Diego and as an assistant controller. His work focuses on business model strategy, business engineering and, more broadly, structural analysis: how companies make money, read from their own filings. He created FourWeekMBA and leads research there and at The Business Engineer, his newsletter on AI and business strategy, with over 95,000 subscribers and more than 1,000 published analyses. His writing has also appeared on Entrepreneur (for example, How to Digitize a Family Business in Europe) and HackerNoon. Find him on LinkedIn and Substack. See how we source.
