This issue has been asked of NHTSA on more than one occasion and their reply is that if the lamp being replaced contains a red reflex reflector and the replacement lamp either does not contain a reflector or the reflector is clear, then the lamp is non-compliant with FMVSS-108. This is because 108 requires a vehicle to have two red reflex reflectors on the rear of the vehicle (less than 80 inches wide).
NHTSA also stated that they are not aware of any red incandescent light bulbs that meet the color requirements of 108, therefore those lamps with clear lenses and red incandescent light bulbs would be non-compliant.
Red LED stop, tail, turn signal lamps however do meet the color requirements of 108 and therefore are compliant with 108 when a clear lens is used providing the replacement lamp does not remove (eliminate) any required equipment such as a reflex reflector.
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