Interpretation ID: aiam2775
Androw Designs
549 Roundhill
Greenwich
CT
06830;
Dear Mr. Brooks: This responds to your January 31, 1978, telephone request askin whether Standard No. 302, *Flammability of Interior Materials*, applies to aftermarket seat covers.; Standard No. 302 is a vehicle standard. As such, it applies to ne motor vehicles prior to their first purchase for purposes other than resale. The standard does not apply to items of motor vehicle equipment, such as seat covers, which are sold to a vehicle's owner subsequent to the vehicle's first purchase.; I would note that, with regard to the installation of interio materials in motor vehicles after the first sale for purposes other than resale, no manufacturer, distributor, dealer, or repair business may knowingly render inoperative a device or element of design (such as flame retardant materials) installed in compliance with an applicable motor vehicle safety standard (15 U.S.C., S1397(a)(2)(A)). Therefore, although the materials you produce may not always be required to meet the requirements of the standard when sold in the aftermarket, there may be situations in which the materials could not be legally installed by a manufacturer, distributor, dealer, or repair business unless they were in compliance with the standard.; Sincerely, Joseph J. Levin, Jr., Chief Counsel