Interpretation ID: aiam1760
Assistant Vice President Engineering
Mercedes- Benz of North America
Inc.
One Mercedes Drive
Montvale
NJ 07645;
Dear Mr. Gerth: This is in response to your letter of December 4, 1974, inquirin whether the license plate mounting bracket and other associated hardware on the front end of the vehicle is covered under the proposed damage criteria of Part 581 and Standard No. 215.; The proposed Part 581 bumper standard (40 FR 10, January 2, 1975) which absorbs Standard No. 215, does not require the attachment of a license plate or equivalent substitute during the frontal pendulum test impacts. In addition, there are no damage criteria specified for license plates.; The proposal does, however, limit the amount of allowable damage to vehicle's exterior surfaces and does not specifically except from compliance, the portion of the vehicle that would serve as the place for license plate attachment. Vehicles manufactured from the date on which this proposal becomes effective until September 1, 1978, would, however, be permitted to incur surface damage to any component of the bumper system that contacts the impact ridge of the pendulum test device during testing. It seems likely that license plate mounting brackets would be located in an area that would be subject to this exception.; Yours truly, Richard B. Dyson, Acting Chief Counsel