Interpretation ID: volvo.crs

Mr. William Shapiro
Director, Regulatory Compliance
and Environmental Affairs
Volvo Cars of North America, Inc.
Volvo Drive
Rockleigh, NJ 07647-0913

Dear Mr. Shapiro:

This responds to your letter of March 11, 1998, requesting the National Highway Traffic Safety Administration (NHTSA) to approve an alternate location for placement of the certification label on vehicles within a new car line, currently designated as "P23," that Volvo plans to introduce into North America beginning in model year 1999. Although you requested confidential treatment of the information contained in the March 11, 1998 letter and in its enclosure, you subsequently withdrew that request. Accordingly, this letter makes reference to certain of that information.

NHTSA's regulations at 49 CFR 567.4(c) prescribe specific locations for the installation of vehicle certification labels, and provide that if none of those locations are practicable, the manufacturer may suggest an alternate location for the agency's approval. As identified in your letter, and in an accompanying drawing, the alternate location for which you have requested approval is on the vehicle's B-pillar, facing the door opening of the rear door on the driver's side. In a subsequent letter, dated March 23, 1998, you state that it is not possible for the certification label to be placed in any of the locations specified in 49 CFR 567.4(c) owing to the size of the label, the corresponding surface geometry of each of those locations, and adhesion difficulties owing to the surface properties at some of those locations.

In specifying locations for the placement of vehicle certification labels, NHTSA's objective is to ensure that those labels may be easily read. The location that you have proposed for vehicles in the P23 new car line would meet this objective. NHTSA therefore approves your request.

If you have any further questions regarding vehicle certification requirements, feel free to contact Coleman Sachs of my staff at 202-366-5238.

Sincerely,
John Womack
Acting Chief Counsel
Ref:567
d.4/29/98