Interpretation ID: aiam3169
Mack Trucks
Engineering Division
P.O. Box 1761
Allentown
PA 18105;
Dear Mr. Brown: This responds to your October 17, 1979, letter asking about the prope certification label for an intermediate manufacturer that alters the tires and rims on a chassis thereby affecting the gross axle and vehicle weight ratings. In your letter, you suggest an abbreviated certification label that would list the manufacturer's name and date of manufacture, and would make the statement that the vehicle will conform to certain standards if the incomplete vehicle document is followed. The agency agrees that this is a correct certification.; Intermediate manufacturers are required to attach labels to vehicle that they modify to indicate that some manufacturing operation has occurred on a vehicle between the manufacture of its chassis and its final manufacture. The intermediate manufacturer is permitted to select, from among a number of certification statements, the statement or statements that accurately represent the nature of the work undertaken by that manufacturer. Therefore, it is not necessary for an intermediate manufacturer to use all of the certification statements on its labels.; In the situation that you describe, the intermediate manufacturer wil make a statement on its label identical to one of the statements made by the chassis manufacturer. Although this appears to be redundant, it is necessary to have the intermediate manufacturer's label on the vehicle making the required certification statement so that a final-stage manufacturer can continue to rely upon the certification labels and upon the statements made in the incomplete vehicle document.; Sincerely, Frank Berndt, Chief Counsel