Interpretation ID: aiam3363
Guenther Auto Works
3908 West Main - 8B
Belleville
Illinois 62223;
Dear Mr. Guenther: This is in reply to your letter of September 26, 1980 providing furthe information on your proposed manufacturing operation. I am pleased you found our earlier response 'most workable and least bureaucratic' and hope that you will find this letter equally so.; A vehicle consisting of a new body on a used chassis, and retaining th same title, is a 'used' vehicle, which does not have to meet the Federal safety standards that apply to new vehicles. If you were using the chassis of vehicles built on or after January 1, 1968, the resulting vehicle would have to meet the standards that applied when the original vehicle was built. However, there were no vehicle safety standards that applied before January 1, 1968 so your contemplated use of a 1964 chassis(of 1965-67 for that matter) frees you totally of responsibility for vehicle safety standards compliance, no matter whether you are a kit supplier or an end assembler, or are using new or reconditioned components.; A few of our safety standards, however, apply to equipment items specifically brake hoses, brake fluid, lighting equipment, tires, glazing, seat belt assemblies, and wheelcovers/hub caps. If you by any of these items from an outside supplier, and the item is manufactured in the U.S.A., it is virtually certain that it will be certified by its manufacturers as meeting federal equipment standards. From your letter, it would appear that only the glazing standard (Standard No. 205) might be of concern to your operations since you write that you 'will have constructed ... glass panes ...' Glazing bearing the designation 'AS-1' must be installed in the windshield of the new body. I am enclosing a copy of Standard No. 205 for your information.; Under the National Traffic and Motor Vehicle Safety Act you are 'manufacturer' with respect to any vehicle equipment you fabricate or vehicle you assemble. This means that in the event a 'safety related defect' developed in your product, you would be obligated to notify the owners and remedy the defect. I enclose our 'Part 573' which tells you haw to file a defect report with us an 'Part 577' which details how you notify purchasers and the optional remedies you may provide (See 577.5 (g)(i)(g)(v) and (g)(vi)). Finally, if you intend to assemble the vehicles yourself, or if you are fabricating glazing (or other item covered by a Federal standard, you should submit the information required by our 'Part 566' which I also enclose.; If you have any further questions we will, of course, be happy t answer them and we appreciate your wish to be informed of your obligations under Federal law.; Sincerely, Frank Berndt, Chief Counsel