Interpretation ID: volvov70.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 January 6, 2000, requesting the National Highway Traffic Safety Administration (NHTSA) to approve an alternate location for placement of the certification label on vehicles within a new, early 2001 model year passenger car line, to be designated as the "Volvo V70," that Volvo plans to begin offering for sale on or about March 15, 2000.

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. You note that by letter dated April 29, 1998, NHTSA approved this same location for the placement of the certification label on vehicles within the Volvo S80 line. You state that the new Volvo V70 shares with the S80 many safety features that involve structural design, and has the same basic vehicle platform as the S80.

Your letter states 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. You state that the alternate location that Volvo has proposed will meet the requirements of 49 CFR 567.4(c) because it is in "the same general area" as the locations specified in that section, and because a label in the proposed location will be "easily readable without moving any part of the vehicle except an outer door."

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 new V70 passenger 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,
Frank Seales, Jr.
Chief Counsel
ref:567
d.2/22/2000