Interpretation ID: aiam0553
III
Fordyce
Wayne
Hartman
Renard & Stribling
Attorneys and Counselors
818 Olive Street
Saint Louis
MO 63101;
Dear Mr. Toney: This is in reply to your letter of October 10, 1972, requestin information on requirements applicable to the trucking industry regarding the reporting of numbers of vehicles produced. You also ask whether a person who adds a fifth wheel to complete a truck is a manufacturer who is subject to the requirements.; Section 573.5(5) of NHTSA 'Defects Reports' regulation (49 CFR Par 573) requires manufacturers of motor vehicles to report, on a quarterly basis, the total number of the manufacturer's vehicles by make, model, and model year, if appropriate, produced or imported during that quarter. This requirement applies to all manufacturers of complete or incomplete motor vehicles, including manufacturers of trucks. A person who adds a fifth wheel to an incomplete vehicle and completes the vehicle is considered to be a manufacturer under section 573.3 of the regulation, and is required to report production figures as part of his quarterly reports.; Yours truly, Richard B. Dyson, Assistant Chief Counsel