Interpretation ID: aiam2700
Assistant General Counsel
Texas Automobile Dealers Association
1108 Lavaca
P.O. Box 1028
Austin
TX 78767;
Dear Mr. Sapp: This responds to your October 5, 1977, letter requesting a furthe clarification of our interpretation given to you on September 1, 1977, concerning 'kit cars.'; You ask whether there is a requirement to certify the vehicle if it i manufactured using an old chassis. As we stated to you in our first letter, the assembly of such a vehicle is not the manufacture of a new motor vehicle. The certification requirements of Part 567 of our regulations apply only to new motor vehicles or the alteration of previously certified vehicles prior to their first purchase for purposes other than resale. Since your remanufacturing operation constitutes neither the manufacture of a new motor vehicle nor the alteration of a previously certified vehicle, your vehicle would not be required to be certified.; Sincerely, Joseph J. Levin, Jr., Chief Counsel