Interpretation ID: aiam0644
Chief
Liaison Engineer
Toyo Kogyo Detroit Office
3841 Mystic Valley Dr.
Bloomfield Hills
Michigan 48013;
Dear Mr. Utsunomiya: This is in response to your letter of March 16, 1972, in which you as whether the definition of 'unloaded vehicle weight' is the same as or 'curb weight' plus optional parts, and whether the definition of 'gross vehicle weight' is the same as that for 'maximum loaded vehicle weight.'; The two sets of definitions are expressed in substantially differen terms. The new terms, 'unloaded vehicle weight' and 'gross vehicle weight rating' are more general than the older ones. The newer terms also eliminate some ambiguities in the definitions based on 'curb weight,' such as just what is meant by 'standard equipment,' and whether other vehicle fluids besides fuel, oil, and coolant should be included. Further, GVWR is a rating, not necessarily identical to any scale weight although some constraints have been placed on it in our Certification regulations (S567.4(g)(3)).; Thus although the two sets of definitions are somewhat similar in thei application, they are different enough that each must be interpreted and used in its own terms.; Yours truly, Richard B. Dyson, Assistant Chief Counsel