Interpretation ID: aiam0349
Jr.
Executive Secretary
Distributors Association
P.O. Box 11088
Cincinnati
OH 45211;
Dear Mr. Pieratt: This is in response to your letter of May 12, 1971, in which yo inquired about the responsibilities, under Parts 567 and 568 of the NHTSA regulations, of a company that sells small trailer chassis in kit form, to persons who assemble them, add bodies, and sell them to users. You discussed the questions by telephone with Richard Dyson of this office on May 21, and this letter confirms the answers that Mr. Dyson gave you then.; Since the unit sold by the company in question is not assembled, it i not an 'incomplete vehicle' within the meaning of Part 568, and the company therefore has no responsibilities under that part to provide information to subsequent purchasers. The person who assembles the kit and adds a body is, of course, a manufacturer, and must certify the complete vehicle under S 567.4 of the Certification regulations. It appears that this certifier would normally rely on the chassis kit seller to provide the basic information concerning the vehicle characteristics, and the assurance that when assembled according to instructions it will conform to applicable motor vehicle safety standards, so that he can responsibly certify the vehicle. We assume that the chassis kit seller would provide this information as a commercial responsibility, although the relationship is not at present governed by NHTSA regulations.; Please let us know if we can be of further assistance. Sincerely, Lawrence R. Schneider, Acting Chief Counsel