Interpretation ID: aiam3738
VIRACON
Inc.
800 Park Drive
Owatonna
MN 55060;
Dear Mr. Richards: This is to follow-up on your phone conversation with Stephen Oesch o my staff concerning the agency's regulations and standards which would be applicable to a sunroof kit that you plan to manufacture as an item of aftermarket motor vehicle equipment. As I understand it, you only plan to manufacture the sun roof kit and have no plans to install the sun roof in vehicles. You were, however, interested in any regulations or standards affecting the installation of such a sun roof kit.; Safety Standard No. 205, *Glazing Materials*, specifies performance an location requirements for all glazing materials used on motor vehicles, whether as original equipment or as replacement (aftermarket) equipment. As a manufacturer or fabricator of glazing you would have to certify that the glazing used in your sun roof complies with all applicable requirements of the standard, a copy of which is enclosed.; Manufacturers of motor vehicle equipment also have specifi responsibilities under the National Traffic and Motor Vehicle Safety Act regarding safety-related defects in their products. Sections 151 *et* *seq*. of the Act requires manufacturers to notify purchasers about safety-related defects in their product and to remedy such defects without charge. A copy of the Act and the applicable defect regulations are enclosed. In addition, Part 556, *Manufacturer Identification*, requires vehicle and equipment manufacturers to provide the agency with certain information concerning themselves and the products they manufacture. A copy of Part 556 is enclosed.; If a sun roof is added to a vehicle before sale of the vehicle to it first purchaser, the vehicle alterer is required by Part 567 of our regulations to certify that the vehicle, as altered, complies with all applicable safety standards. A copy of Part 567 is enclosed. If the sun roof is added by a manufacturer, dealer, distributor, or repair shop after the sale of the vehicle to its first purchaser, the vehicle does not have to be recertified. Such businesses are, however, prohibited from knowingly rendering inoperative any device or element of design installed in a vehicle in compliance with any safety standard. Thus, for example, they would have to ensure that they do not install the sun roof in such a way that the vehicle no longer complies with Standard No. 216, *Roof Crush Resistance*, a copy of which is enclosed.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel