Interpretation ID: aiam2906
Mack Trucks
Inc.
P.O. Box 1761
Allentown
PA 18105;
Dear Mr. Brown: This responds to your October 10, 1978, letter asking whether you ar permitted to mark the certification documents of some of your incomplete vehicles as MACK TRUCKS, INC./RVI. These incomplete vehicles will be manufactured abroad by Renault Vehicules Industriels and imported in the United States by Mack Trucks, Inc.; Part 568, *Vehicles Manufactured in Two or More Stages*, requires a incomplete vehicle manufacture to furnish with the incomplete vehicle certification its name and mailing address. Section 102(5) of the National Traffic and Motor Vehicle Safety Act states that the term manufacturer includes any person importing motor vehicles or motor vehicle equipment. Since your company will be importing these incomplete vehicles and an importer may be considered a manufacturer, it is permissible for you to label incomplete vehicles assembled by Renault with the MACK TRUCKS, INC./RVI designation.; Sincerely, Joseph J. Levin, Jr., Chief Counsel