TO:  Manufacturers, Distributors, and Massachusetts Dealers    

FROM:  Ben Ford, Legislative Chairman  

DATE:  April 13, 2005

SUBJECT:  Massachusetts House Bill 2139

Representative John Scibak has introduced this bill that will require the     placement of a label on all vehicles with window tinting that certifies the           films’ compliance with the visible-light transmittance and reflectance           statutes. 

As written, this bill will be retroactive from January 1, 2006.  This will            cause the owners of all vehicles tinted prior to that date to obtain a label          from the person who installed the film on their vehicle.  The label size and placement will be determined by the Commissioner of Public Safety and          must be provided by the film manufacturer after proof of the legality of the   product has been offered to the commissioner.

The IWFA is opposed to the use of labels as an enforcement device and         feels that the application of the law to vehicles tinted before the effective      date will create problems for long-time consumers of window tinting products.  Additionally, labels are easily replicated and can pose a problem if          secondary tinting is applied over legal aftermarket film.

The current statutes in Massachusetts are extremely effective and have            been used as an example throughout the rest of the country as excellent      window tinting laws.  The proposed changes are unnecessary.  IWFA                 e encourages all Massachusetts members to contact their legislators and ask         them to vote against HB 2139.