Interpretation ID: aiam2880
Executive Director
Truck Equipment & Body Distributors Association
25900 Greenfield Road
Oak Park
MI 48237;
Dear Mr. Carney: This responds to your September 12, 1978, letter asking severa questions about the applicability of the certification regulations to various manufacturers. In particular, you want to know when a manufacturer is considered an intermediate or a final-stage manufacturer for purposes of applying the regulations.; Part 568, *Vehicles Manufactured in Two or More Stages*, clearl defines incomplete, intermediate, and final-stage manufacturers. Using those definitions, you should be able to determine the certification responsibilities of any manufacturer based upon the manufacturing operation.; From the facts described in your letter, it is not possible for th agency to state with certainty whether a body installer would be an intermediate manufacturer or a final-stage manufacturer. These classifications depend upon the type of manufacturing done by each manufacturer. If the body installer performs such operations on an incomplete vehicle, as defined in Part 568, that the vehicle becomes a completed vehicle, then the body installer would be considered a final-stage manufacturer. A completed vehicle is also defined in Part 568. A manufacturer subsequently installing a refrigeration unit would be an alterer of that vehicle. If, on the other hand, the body installer is not performing final-stage manufacturing operations, then it must certify as an intermediate manufacturer. This would occur when, for example, the vehicle was not completed in a manner enabling it to be used on the highways without some further manufacturing operations.; The National Highway Traffic Safety Administration (NHTSA) through it certification regulations is simply requiring that each manufacturer certify the compliance of the vehicle to the extent possible given its manufacturing operations. If a manufacturer makes a good faith determination that it is a certain type of manufacturer or alterer, the NHTSA is likely to accept the certification so long as the appropriate label for that type of manufacturer is attached to the vehicle in the manner prescribed by the regulations.; Sincerely, Joseph J. Levin, Jr., Chief Counsel