Interpretation ID: 1982-1.4
TYPE: INTERPRETATION-NHTSA
DATE: 01/12/82; JANUARY 13, 1982
FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA
TO: Pathfinder Auto Lamp Company
TITLE: FMVSS INTERPRETATION
TEXT: This responds to your November 25, 1981, letter to Roger Tilton of this Office regarding the applicability of vehicle identification number (VIN) requirements to trailer kits manufactured by your company.
It is our view that these trailer kits must comply with the VIN requirements of FMVSS 115. Your kits contain all components necessary to assemble a complete trailer, and are advertised as capable of being readily assembled with simple tools such as screwdrivers and wrenches. We see no relevant basis for distinguishing between such kits and completed trailers for purposes of determining the applicability of FMVSS 115.
While the VIN requirements do provide anti-theft benefits, they also are important to this agency in administering the defect recall program as well as to State motor vehicle departments and insurance companies. Further, even if this agency exempted trailer kits from VIN requirements, purchasers of your kits would likely face difficulties when they attempt to register their trailers with the States. We expect most states to soon begin checking VIN's as part of the vehicle registration process, and vehicles without a VIN or with a nonconforming identification number might face rejection by the state motor vehicle departments notwithstanding a technical exemption from NHTSA. We feel that in the long run, the best and simplest solution is for vehicle manufacturers to assign a VIN which meets the requirements of FMVSS 115.
Should you still wish to seek an exemption from the standard, procedures for obtaining exemptions are set forth in Title 49 of the Code of Federal Regulations, Part 555, a copy of which is enclosed. Such exemptions are available for not more than three years.
You should also be aware that certification labels must contain both the month and year of a vehicle's manufacture. See 49 CFR 567.5(b)(5). The copy of the label you sent us contains only the year of manufacture.
If you have further questions on this matter, feel free to contact us again.
Sincerely,
Enclosure
ATTACH.
Pathfinder Auto Lamp Company
November 25, 1981
Roger Tilton -- Office of the Chief Counsel, National Highway Traffic Safety Administration
RE: V.I.N. REQUIREMENTS FOR COMPACT UTILITY TRAILER KITS
Dear Mr. Tilton:
In accordance with our telephone conversation of November 24, 1981, I have enclosed information on our trailer kit consisting of the following:
- Sales Brochure
- Picture of the Unit
- Copy of the Nameplate Label
- Copy of the M.S.O. (C.O.)
A question has occurred in one state regarding the application of FMVSS 115 (576.115) requirements for Vehicle Identification Numbers (V.I.N.) to these trailer kits. The problem being that to comply with the requirements of 115 would impose a workload on us that cannot be justified based on the unit volume and low selling cost of these units.
We have no problems in working with the various agencies in the several states and meeting their various legal, administrative, taxing, and construction requirements for these units, even though they represent a new or separate category in some cases. However, the 115 requirements present a burden which can cause restricted availability in jurisdictions imposing them. This is unfortunate for consumers in those locales, particularly since these units are a natural adjunct to down size cars with limited trunk space.
While the requirements of 115 are a definite improvement in regard to protecting motor vehicles and other high dollar items from theft, we feel that the requirements are not completely logical for these kits. The reason being that these units are low in dollar value at retail and are not a theft prone item. The latter is true especially prior to assembly since the kit still in the box is not very mobile due to the size and weight of the box. We therefore seek your assistance in resolving this matter since our customers are anxious to sell these units in all states.
I appreciate your assistance in this matter. Please feel free to call me if I may be of further help to you.
Very truly yours,
James S. Nasby -- Director of Engineering
enclosures (4)
COMPACTUTILITY TRAILER 1/2 TON CAPACITY
(Graphics omitted)
STORAGE
Unique design of recessed tail lights permits trailer to be easily stored in an upright position. This exclusive feature saves considerable storage space in garage, shed or basement.
CLAM SHELL
The 48 x 41 trailer frame is designed to accommodate most clam shell car top carriers. The rear cross member of the trailer frame adjusts to fit the various mounting spans of manufactured clam shell carriers.
FLAT BED
A versatile flat bed trailer can be built in minutes by simply bolting on a 48' x 41' plywood board to the trailer frame. Additional mounting holes are provided on all four sides of the frame to accommodate tie down cords.
EASY TO ASSEMBLE
All that is required to assemble the trailer is a screwdriver a (Illegible Word) allen wrench and two adjustable wrenches. The assembly time can be greatly reduced with the use of a 1/4" socket set and several open and wrenches.
(Graphics omitted)
Demountable wheel permits easy tire changing and lubrication. Spare tire available separately CT-1010 (02010)
This beautifully designed consumer oriented package contains self selling features which includes explicit application information and product specifies. The entire unit is packaged in a surprisingly compact box and measures 49 1/2" x 21 1/2" x 5 5/8".
Optional fenders constructed of heavy gauge steel are available as separate item. CT-1020(02020)
BOX
The versatility of the frame is enhanced to its utmost when converting the unit to a box trailer. Complete building plans are provided in the instruction manual which will make this an easy job for the "do it yourselfer."
WINTER USE
The 1,000 lb. load capacity of the trailer gives it a wide assortment of winter season uses ranging from hauling a snowblower to most snowmobiles. This added feature gives truth to the fact that it is truly an item for all four seasons.
MOTORCYCLE
The trailer frame can be easily converted to transport most motorcycles and bicycles. It is ideal for off road dirt bikes as well as family bicycle outings.
GARDEN TRACTOR
In whatever configuration the trailer frame is transformed, it can be used with most garden tractors. The compact utility trailer is at least less than 1/2 the cost of most standard garden tractor trailers and yet has greater universal application.
* Each trailer comes complete with easy to read assembly instructions.
* A certificate of origin, which is required in most states for title and licensing, is included with each trailer.
* The trailer is equipped with DOT approved class "A" lighting which meets legal requirements in all 50 states and Canada.
* Pathfinder's hub and sprindle are fully assembled with bearings and seal factory greased and installed.
Master Master Model IBM Carton Carton Carton No. No. Pack Weight Cube CT-1000 02001 1 125 3.39
MANUFACTURED BY Pathfinder Niles, IL, U.S.A. 60648
Date of Manufacturer: 1980
Model No.: CT 100
Serial No: 2275
GVWR 1100 LBS. WITH 480/400x8 TIRES AT 60 P.S.I. COLD
GAWR 1100 LBS. WITH 480/400x8 TIRES AT 60 P.S.I. COLD
MAXIMUM LOAD CARRYING CAPACITY 1000 LBS.
THIS VEHICLE CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE STANDARDS IN EFFECT ON THE DATE OF MANUFACTURE SHOWN ABOVE.
Manufacturer's Statement or Certificate OF ORIGIN TO A UTILITY TRAILER
The undersigned manufacturer hereby certifies that the new Trailer kit described below, the property of said manufacturer has been transferred this day of 19 on Invoice No. to whose address is
Trade Name of Trailer kit: Compact Utility Trailer
Serial No.
Shipping Weight: 123 lbs.
Maximum Load Carrying Capacity: 1,000 lbs.
G.A.R.W.: 1,100 lbs.
Date of Manufacture (and Model Year)
MONTH
YEAR
Series or Model Name: CT1000
No. Wheels: 2
Width: 40 (Illegible Word)
Length: 44"
G.V.W.R.: 1,100 lbs.
Other Data: Steel Construction Black
(Illegible Line)
Said manufacturer hereby certifies that this written instrument constitutes the first conveyance of said vehicle after its manufacture and that the manufacturer's serial number set forth above has not been and will not be used by the manufacturer on any other vehicle manufactured by said manufacturer, and that there are no other manufacturer's certificates issued by the manufacturer for the vehicle described above.
PATHFINDER AUTOLAMP CO. NILES, ILLINOIS 60648
MANUFACTURER
By:
(SIGN NAME TITLE OR POSITION)
(Graphics omitted)