HB 1361, the Collision Avoidance Systems Act of 2025, would remove regulatory ambiguity by deeming FMVSS 108 to permit pulsating light systems on high-mounted brake lamps. It directs a rulemaking process to update the standard with performance-based criteria and to allow use of these systems on motor vehicles.
The bill also establishes a precise technical definition for pulsating lamps and sets timing constraints to prevent unpredictable signaling. Taken together, the bill creates a regulatory pathway for a new safety feature aimed at reducing rear-end collisions.
At a Glance
What It Does
Beginning on enactment, Standard 108 will be deemed to allow pulsating light systems on high-mounted stop lamps. The Secretary of Transportation must issue regulations within 180 days to update Standard 108 with performance-based standards and to permit these systems.
Who It Affects
Automakers and lighting suppliers developing high-mounted stop lamps; regulatory compliance teams within vehicle manufacturers; federal transportation agencies responsible for FMVSS 108.
Why It Matters
Provides a clear, regulatory path for a potentially safer signaling technology, reducing uncertainty for manufacturers and accelerating potential safety benefits while ensuring standardized testing criteria.
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What This Bill Actually Does
The Collision Avoidance Systems Act of 2025 creates a formal, federal pathway for pulsating high-mounted stop lamps. It resolves ambiguity by treating FMVSS 108 as allowing such pulsating lamps for vehicles covered by the standard.
The bill requires the Department of Transportation to publish updated, performance-based regulations within 180 days to govern these systems and their use on motor vehicles. It also provides precise definitions that distinguish pulsating lamps from traditional stop lamps and sets behavior rules to ensure signal clarity during braking.
With these provisions, the Act aligns regulatory language with a new signaling technology while preserving a consistent signaling language in the field.
The Five Things You Need to Know
FMVSS 108 is deemed to permit pulsating high-mounted stop lamps from enactment.
DOT must issue updated, performance-based standards within 180 days.
A pulsating light system is defined as up to 4 rapid pulses (1.2 seconds total) before returning to continuous light.
Pulses may not recur within 5 seconds after brake release, ensuring signal stability.
Scope applies to motor vehicles governed by FMVSS 108.
Section-by-Section Breakdown
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Short title
This act may be cited as the Collision Avoidance Systems Act of 2025. The short title provides the formal reference point for the act and signals its applied focus on collision avoidance technologies integrated with vehicle signaling.
Clarification on pulsating light system eligibility
Beginning on the date of enactment, Standard 108 shall be deemed to allow the use of a pulsating light system on vehicles covered by that Standard. This clarifies regulatory interpretation and removes ambiguity that could impede the deployment of pulsating high-mounted brake lamps.
Rulemaking deadline and scope
Not later than 180 days after enactment, the Secretary of Transportation shall issue regulations necessary to update Standard 108. The updates must establish performance-based standards for pulsating light systems and authorize their use on motor vehicles, creating concrete regulatory criteria to guide manufacturers and compliance programs.
Definitions
Definitions establish the term pulsating light system and specify the scope of Standard 108. The pulsating light system is defined as a system for a high-mounted brake lamp that, when braking, pulses rapidly no more than four times and for no more than 1.2 seconds, then remains continuous until brake release; pulses may not repeat for at least five seconds after brake release. Standard 108 is defined as the federal safety standard governing motor vehicle signaling equipment (FMVSS 108).
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Automakers and lighting suppliers developing high-mounted stop lamps, who gain regulatory clarity and a predictable path to market for new signaling tech.
- Commercial and consumer vehicle owners, who may benefit from enhanced brake signaling clarity and potential reductions in rear-end collisions.
- Fleet operators and commercial carriers employing advanced signaling systems to improve safety and reduce accident risk.
- Regulatory agencies (DOT/NHTSA) that gain a clear framework for updating signaling standards and enforcing compliance.
- Insurance industry stakeholders tracking risk reductions associated with improved signaling technology.
Who Bears the Cost
- Automakers and lighting suppliers bearing design, testing, certification, and potential tooling costs to meet updated standards.
- Regulatory agencies incurring costs for rulemaking, stakeholder engagement, and ongoing oversight.
- Dealerships and service networks bearing costs related to stocking, installing, or retrofitting new lighting hardware.
- Consumers potentially facing higher upfront vehicle prices due to added lamp hardware and certification expenses.
- Small-volume manufacturers that face disproportionate per-unit regulatory costs when adopting new standards.
Key Issues
The Core Tension
The central dilemma is balancing a potential safety gain from clearer braking signals against the risk of driver confusion or inconsistent signaling across vehicles during the transition to pulsating stop lamps.
The act introduces a clear safety mechanism by enabling pulsating high-mounted stop lamps, but it also raises questions about signal interpretation and uniform enforcement. While the performance-based standard approach allows for innovation and evaluation of real-world effectiveness, it requires robust testing, compatibility checks with existing signaling conventions, and careful monitoring of potential driver adaptation issues.
Implementation could be uneven across vehicle classes and markets if the rulemaking process encounters resource constraints or if phased rollouts occur. Policy designers will need to watch for unintended signaling confusion in multi-vehicle environments and ensure aftermarket retrofits meet the same performance criteria as factory-installed systems.
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