Interpretation ID: aiam2494
Executive Vice-President
Caravan Trailer Rental Co. Ltd.
955 Middlegate Road
Mississauga
Ontario
Canada L4Y3Y4;
Dear Mr. Livingston: This responds to Caravan Trailer Rental Company's December 22, 1976 question whether trailers manufactured prior to January 1, 1975, may be imported into the United States for sale without being required to conform to Standard No. 121, *Air Brake Systems.*; Standard No. 121 only regulates the manufacture and importation o trailers that are produced on or after January 1, 1975. Standard No. 121's only limitation on the importation and sale of trailers manufactured prior to January 1, 1975, would be that any repair, refurbishment, or other modification of the trailer must not be so significant as to constitute the manufacture of a new vehicle. To qualify as a repair the NHTSA requires that the running gear assembly of the existing trailer be used in the refurbished trailer and that certain other identification and ownership (or leasing) aspects of the existing trailer be continued in the refurbished trailer. I have enclosed a copy of a notice which explains the NHTSA regulations in this area.; You are reminded that a trailer imported into the United States as yo describe must bear a label that states the month and year of manufacture.; Sincerely, Frank Berndt, Acting Chief Counsel