Interpretation ID: aiam2412
Frink Sno-Plows
205 Webb Street
Clayton
NY 13624;
Dear Mr. Stitt: This responds to your September 29, 1976, request to know th responsibilities of a manufacturer of motor vehicles under the National Traffic and Motor Vehicle Safety Act (the Act) (15 U.S.C. S 1381, *et seq*.). The information you request appears in Title 49 of the Code of Federal Regulations, and I enclose an information sheet which explains how this material may be obtained. I have also enclosed copies of several of the pertinent regulations.; Part 566, *Manufacturer Identification (49 CFR Part 566), specifie identification information which must be submitted to the NHTSA by manufacturers of vehicles and equipment regulated by our standards.; Part 567, *Certification* (49 CFR Part 567), specifies the content an location of the certification label or tag that must be attached to motor vehicles regulated by our standards. After a manufacturer has certified a motor vehicle, persons who alter it, other than by the addition, substitution, or removal of readily attachable components such as mirrors or tire and rim assemblies (or minor finishing operations such as painting), and persons who change the vehicle's weight ratings, must be able to state that, as altered, the vehicle continues to comply. The requirements for such alterers appear at S 567.7 and S 568.8 of NHTSA regulations. An example of a significant alteration is mounting of a snowplow to a certified vehicle.; It is common practice in the truck industry to manufacture vehicles i two or more stages, often by the manufacture of a cab-chassis by a large volume manufacturer, followed by the installation of a body or piece of work-performing equipment by a smaller manufacturer in the locality where the truck is being purchased. To assign responsibilities for the certification of such 'multi-stage' vehicles, the NHTSA has issued Part 568, *Vehicles Manufactured in Two or More Stages* (49 CFR Part 568). The manufacturer of an 'incomplete vehicle' (such as a cab-chassis) must provide documentation to the intermediate and final-stage manufacturer of the vehicle on how to complete it so that it complies with all applicable standards. It is the responsibility of the final- stage manufacturer to affix the certification label discussed earlier, unless the incomplete- or intermediate-stage manufacturer assumes this responsibility.; In some cases, the two- stage process involves mounting a used body o a new chassis or mounting a new body on an old chassis. It is only when a new chassis is involved that the NHTSA considers the operation to be the manufacture of a new vehicle.; Sincerely, Frank A. Berndt, Acting Chief Counsel