Interpretation ID: aiam4218
Jr.
Amilite Corporate
666 Old Country Road
Garden City
NY 11530;
Dear Mr. Fennell: Thank you for your letter of July 30, 1986, concerning the markin requirements of Standard No. 205, *Glazing Materials*. You explained that your company represents several glazing manufacturers that make windshields. You said that your company sometimes receives orders from other companies asking to have a windshield made for them with their own corporate logo marked on the windshield. You asked if a company can, with the permission of the other company, mark a windshield with the other company's logo and its own DOT identification number. As discussed below, such a practice is permissible.; Section 6 of Standard No. 205 sets forth the certification and markin requirements for glazing materials. Section 6.1 requires a prime glazing manufacturer to mark each item of glazing material in accordance with section 6 of American National Standard 'Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways,' Z-26.1-1977, January 26, 1977, as supplemented by Z26.1a, July 3, 1980 (ANS Z-26). One of the requirements of S6 of ANS Z-26 is that a manufacturer mark its glazing with its own 'distinctive designation or trademark.' In addition to those requirements, S6.2 of Standard No. 205 requires a prime glazing manufacturer to mark each item of glazing material designed to be used in a specific vehicle with the symbol 'DOT' and a manufacturer code mark assigned by this agency. The standard defines a prime glazing manufacturer as 'one who fabricates, laminates, or tempers the glazing material.'; One reason for the marking requirements of Standard No. 205 is to ai the agency in identifying the actual manufacturer of the glazing for the purpose of defect and noncompliance recall campaigns. Since, in the situation you described, the prime glazing manufacturer will be placing its own DOT code mark on the glazing, the agency's ability to identify easily and accurately the manufacturer of the glazing will not be impaired. Therefore, we would not consider the use of another manufacturer's logo on the glazing to be a violation of the standard as long as the prime glazing manufacturer has marked the glazing with its own DOT code mark.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel