Interpretation ID: aiam2709
Vice President
Lowe Machine Company
State Route #2
Rural Route #3
Oak Harbor
OH 43449;
Dear Mr. Lowe: This responds to your October 12, 1977, letter asking what regulation apply to you in your capacity as an alterer of motor vehicles. The National Highway Traffic Safety Administration (NHTSA) promulgates safety standards for motor vehicles. The agency requires persons who alter motor vehicles prior to their first purchase for purposes other than resale to attach a label to each vehicle indicating that it continues to comply with all applicable safety standards. Therefore, if the modification that you intend to perform occurs prior to the first purchase of the vehicle for purposes other than resale, you would be required to attach such a label. I am enclosing a copy of Part 567, *Certification* (Volume 49 of the Code of Federal Regulations, Part 567) which addresses the responsibilities of vehicle alterers.; If you modify vehicles after their first purchase for purposes othe than resale, then you need not attach a certification or alterer's label. However, section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act of 1966 (the Act) (15 U.S.C. 1381 *et seq*.) prohibits any repair business, dealer, distributor, or manufacturer from rendering inoperative any device or element of design installed on a vehicle in compliance with a safety standard. If your manufacturing operation affected the compliance of any aspect of the vehicle with safety standards in effect on the date of the vehicle's manufacture, you would be in violation of the Act and subject to civil penalties prescribed thereunder.; Sincerely, Joseph J. Levin, Jr., Chief Counsel