Interpretation ID: aiam3019
24 Wedgemere Road
Malden
MA 02148;
Dear Mr. Trioli: This responds to your recent letter requesting information concernin the Federal requirements that would be applicable to auxiliary propane fuel systems for automobiles, which you would like to market in the United States.; Federal Motor Vehicle Safety Standard No. 301-75, *Fuel Syste Integrity*, (copy enclosed) specifies performance requirements for fuel systems on motor vehicles. Although the standard applies to completed vehicles rather than to fuel tanks or other fuel system components, there are requirements of which you should be aware if you intend to market auxiliary fuel systems. An original vehicle manufacturer that uses your auxiliary system, General Motors for example, has to certify that the entire vehicle complies with all applicable safety standards.; A person who mounts an auxiliary fuel tank or system on a new moto vehicle before the vehicle's first purchase in good faith for purposes other than resale is a vehicle alterer under the National Highway Traffic Safety Administration regulations. That person is required by 49 CFR 567.7 (copy enclosed) to affix a label to the vehicle stating that, *as altered*, the vehicle conforms to all applicable Federal Motor Vehicle Safety Standards--including Standard No. 301-75.; In addition, the mounting of an auxiliary or replacement fuel tank on motor vehicle after the vehicle's first purchase in good faith for purposes other than resale is affected by Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1397(a)(2)(A)). That section specifies in relevant part that:; >>>No manufacturer, distributor, dealer, or motor vehicle repai business shall *knowingly render inoperative*, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard.... (Emphasis added.)<<<; Therefore, the mounting of an auxiliary fuel tank or system on a use vehicle must be performed in such a way that the vehicles's compliance with Standard No. 301-75 is not knowingly compromised.; Sincerely, Frank Berndt, Chief Counsel