Interpretation ID: aiam2587
Chief Product Engineer
E.D. Etnyre & Co.
200 Jefferson Street
Oregon
IL 61061;
Dear Mr. Decker: This responds to your March 30, 1977, letter asking whether th rebuilding of a motor vehicle with all new running gear and an old body constitutes the manufacture of a new motor vehicle requiring compliance with Federal regulations.; In the rebuilding operation you describe, you retain the old body tan structure while replacing the entire running gear assembly. The National Highway Traffic Safety Administration (NHTSA) has determined by regulation in 49 CFR 571.7(f) that the rebuilding of a motor vehicle using old running gear with a new body does not constitute the manufacture of a new motor vehicle. The vehicle will be considered newly manufactured unless, at a minimum, the trailer running gear assembly is not new and was taken from an existing trailer whose identity is continued with respect to the Vehicle Identification Number. In addition, the trailer must be owned or leased by the same party both before and after the remanufacture. Since the running gear with which you plan to equip your vehicle is new, your operation constitutes the new manufacture of a vehicle.; You ask secondly what portion of the running gear can be replaced a normal repairs without such replacement being considered the manufacture of a new vehicle. You may replace any part of the running gear assembly that breaks or malfunctions during operation of the motor vehicle. The NHTSA would consider this to be normal maintenance of the vehicle, not subject to the requirements applicable to vehicle manufacture.; Sincerely, Joseph J. Levin, Jr., Chief Counsel