Interpretation ID: aiam2522
President
Treon Mfg. Corp.
8000 Cooper Avenue
Glendale
NY
11227;
Dear Mr. Wolinsky: This responds to your February 4, 1977, question whether Standard No 302, *Flammability of Interior Materials*, applies to materials supplied to the aftermarket for use in vans.; Standard No. 302 does not directly apply to aftermarket materials o components. As a vehicle standard it applies only to those original components or materials of new vehicles specified in paragraph S4.1 of the standard and installed in a vehicle prior to its first sale for purposes other than resale (15 U.S.C. S1397(b)(1)). Therefore, materials that you supply to the final vehicle purchaser are not subject to the requirements of the standard.; I would also note that, with regard to the installation of interio materials in motor vehicles after the first sale for purposes other than resale, no manufacturer, distributor, dealer, or repair business may knowingly render inoperative a device or element of design (such as flame retardant materials) installed in compliance with an applicable motor vehicle safety standard (15 U.S.C. S1397(a)(2)(A)). Therefore, although the materials you produce may not always be required to meet the requirements of the standard when sold in the aftermarket, there may be situations in which the materials could not be legally installed by a manufacturer, distributor, dealer, or repair business unless they were in compliance with the standard.; Sincerely, Frank A. Berndt, Acting Chief Counsel