Interpretation ID: aiam3129
VDO-ARGO Instruments Inc.
980 Brooke Road
P.O. Box 2630
Winchester
Virginia 22601;
Dear Mr. Ritzenthaler: This is in response to your letter of January 25, 1979, in which yo stated your interpretation of Federal Motor Vehicle Safety Standard 127, *Speedometers and Odometers*, and asked that we advise you if action taken in accordance with this interpretation would place your company in violation of the standard. This letter is to confirm that your interpretation is correct.; According to your interpretation of Safety Standard 127, thos provisions which become effective for new motor vehicles on September 1, 1979 and September 1, 1980 are not applicable to speedometers and replacement parts produced for use in motor vehicles manufactured before those dates. This is correct because Safety Standard 127 is a vehicle standard and an equipment standard which applies to passenger cars, multipurpose passenger vehicles, trucks, motorcycles, and buses manufactured after the standard's effective dates and to speedometer and odometers for use in such vehicles. (Section 3, Safety Standard 127).; Sincerely, Frank Berndt, Chief Counsel