NHTSA Cyan Lamp Proposal Rewrites Lighting Rules for Robotaxis

A small rule with a big signal

Federal vehicle safety rules were written on the assumption that a person sits behind the wheel. The National Highway Traffic Safety Administration is now taking that assumption out of the rules one standard at a time. On October 23, the agency proposed changes to Federal Motor Vehicle Safety Standard No. 108, the federal lighting standard. The changes would update lighting requirements for vehicles built to be driven only by automated driving systems, and they would set performance criteria for marker lamps that identify those vehicles.25 The notice appeared in the Federal Register on October 26, and the public can comment until November 25.29

The changes sound technical, but the proposal matters for two reasons. It is the most visible step so far in a year-long effort to clear legal obstacles for vehicles with no steering wheel or pedals. It also arrives as the robotaxi business moves from pilot projects toward scale, with Waymo far in front. Together, the regulatory change and the commercial expansion make it likely that the next few years of autonomous driving will be decided as much by federal rulebooks as by software.

What the proposal actually does

The headline feature is cyan, a blue-green color. Under the proposal, manufacturers could add cyan ADS marker lamps to passenger cars, multipurpose vehicles, trucks and buses, but they would not be required to. A vehicle could carry one or two lamps on the front, on each side and on the rear, all mounted at least 15 inches off the ground.21 The lamps would come on only when the automated system is driving. They could never be lit while a person is driving, and they would all switch on and off together.27 That means a car running a supervised driver-assistance system, such as Tesla's Full Self-Driving (Supervised), could not use them.29

The rest of the proposal removes requirements that make no sense without a driver. Physical controls for turn signals, hazard lights and high beams would be required only on vehicles that have manual driving controls.21 For vehicles without a steering wheel, turn signals would no longer have to cancel when the wheel turns back or when someone presses a switch. They would still need a turn-signal operating unit, but it would no longer have to be manual.26 Some of the dashboard indicators tied to those controls would also go.29

Two changes reach well beyond robotaxis. Integrated headlamps could be tested at a voltage the manufacturer specifies instead of the fixed 12.8 volts set in 1967. The rule requiring the low beam to sit above the high beam in a vertically stacked headlamp would also be dropped.29 Those changes would apply to all vehicles, not only driverless ones. That is easy to miss when coverage focuses on the novelty of cyan lights.

NHTSA describes the changes as removing unnecessary requirements and adding design flexibility without affecting safety.28 The agency also wants comment on a federalism question: whether states should be barred from requiring the lamps. If they were, the choice would rest with manufacturers. The agency says it does not know of any state law that currently requires or bans the lamps.29

Part of a deliberate sequence

The lighting notice is one piece of a coordinated campaign. In September 2025, Transportation Secretary Sean Duffy said NHTSA would propose rules modernizing safety standards for automated vehicles, covering shift levers, defrosters and lighting equipment.19 In March 2026, the agency proposed removing the transmission shift display requirement from FMVSS No. 102 for vehicles without manual controls.11 A June proposal would drop the manual brake pedal requirement for vehicles designed to operate only autonomously.18 In July, NHTSA Administrator Jonathan Morrison told CNBC the agency would "absolutely" consider ending the requirement for manual controls, saying such requirements make no sense for vehicles never meant to be driven by a person.14

According to the agency, the agenda also includes upcoming work on controls and displays, mirrors, electronic stability control, sun visors and warning labels. Alongside that, NHTSA is expanding exemption programs and developing its first performance standard specifically for automated driving system safety.25 The lighting changes are also separate from a negotiated rulemaking announced earlier in October, which is expected to address other parts of FMVSS No. 108.23

The historical point matters here. In March 2022, NHTSA finalized occupant-protection rules that allowed vehicles without driving controls to comply with federal standards. That rule handled crash safety. The 2026 work handles the remaining requirements that still assume a driver. Before this, the main option was exemptions. Reporting has described those as capped at 2,500 vehicles per manufacturer per year, which would limit any fleet trying to grow nationwide.12 Changing the standards themselves, instead of granting waivers, is what would make high-volume driverless vehicle programs possible.

The Tesla question, and where coverage splits

Coverage agrees on what the rule says. It splits on who it is for. Some Tesla-focused outlets reported that NHTSA named the Cybercab directly in its filing.22 Other analysis found that the official announcement describes automated vehicles in general terms and treated the Cybercab link as unconfirmed.26 The agency's own press release refers to vehicles designed to be driven only by automated systems and does not name a brand.25

Jalopnik's reading was sharper. It called the changes "conveniently Tesla-specific," argued that the Cybercab is the only vehicle on American roads without physical driving controls, and pointed to Elon Musk's political donations.13 That claim about exclusivity looks overstated. Zoox's purpose-built robotaxi, which has no steering wheel or pedals, already carries paying riders on the Las Vegas Strip.2 Earlier comment filings also showed that Waymo and Zoox, not just Tesla, said the revised rules would lower their compliance costs.18

On the substance, the narrower reading holds up better. The relief depends on vehicle design, not brand. Any vehicle without manual controls qualifies, and conventional cars are untouched.26 Tesla is still the most visible beneficiary, though, and the timing is awkward. Last month NHTSA opened an audit query into how Tesla certified the Cybercab, given that it lacks mirrors, pedals and a steering wheel, all of which the current standards require.24 The agency is rewriting the rules while enforcing the old ones against the company that stands to gain the most from the change. That makes the comment record worth watching.

Waymo's scale makes the stakes concrete

The rulemaking comes as robotaxis become a real business. Waymo runs public, fully driverless rides in 15 U.S. metro areas. It has roughly 4,000 vehicles and about 500,000 paid rides a week, and it has a stated goal of 1 million weekly rides by the end of 2026.2 On October 14 it opened San Antonio, San Diego and Tampa to all riders.8 It added rides at Nashville's airport on October 13 and Las Vegas Harry Reid on October 21.2

The money is growing too. Waymo took on its first debt financing, a $5 billion loan led by PIMCO, Blackstone and Sixth Street, after raising $16 billion from investors earlier in the year.3 Semafor and Reuters reported plans to double the fleet to 8,000 vehicles by the end of 2026 and reach 20,000 by the end of 2027. These are reported targets, not confirmed totals.4 Expansion abroad is also under way, with Toronto aimed at 20288 and Madrid at 2027.6

For an operator growing that fast, a national standard for cyan lamps is useful. The Verge noted that NHTSA wants Waymo, Nuro, Zoox and automakers to adopt one consistent design instead of a confusing mix of colors.24 If states are barred from writing their own lamp rules, a fleet that runs in Phoenix, Miami and Las Vegas avoids one more state-by-state compliance problem.29

The safety debate hasn't gone away

Safety advocates are not opposed to the cleanup, but they say it is one-sided. Researcher Philip Koopman has argued that while NHTSA removes barriers, the safety standards still contain no parts written specifically for autonomous vehicles, and that adding them is overdue.18 Advocates for Highway and Auto Safety criticized an earlier proposal for offering no research on how removing displays might affect passengers and first responders. AAA has called for transparency for people who may not know how to deal with a vehicle that has no controls.18

The lighting proposal partly answers those concerns. A cyan lamp is a way of telling police and pedestrians that no human is driving,29 and that comes as NHTSA has pushed developers to address a "clear pattern" of driverless vehicles interfering with emergency scenes.12 Even Electrek, which welcomed the turn-signal change as reasonable, warned that the broader loosening of rules deserves close attention.27 On the data side, IIHS has said the current reporting system is not adequate to monitor a large-scale expansion continuously.2

The bottom line

The direction of the policy is clear: Washington is rebuilding vehicle safety law around the idea that some cars will never have a driver. The proposal itself is sensible and narrow. Turn-signal cams and high-beam stalks do nothing in a vehicle with no hands to use them. The bigger questions are the ones this rule leaves open. One is whether NHTSA will match its deregulatory pace with real performance standards for automated driving. The other is whether it will police certification as firmly as it rewrites the rules. With Waymo planning to grow its fleet several times over and Tesla's Cybercab under audit, the next year will show whether the agency can do both.