Interpretation ID: aiam3830
Chief Operating Office
Nissan Research & Development
Inc.
P.O. Box 8650
Ann Arbor
MI 48104;
Dear Mr. Tanuma: This responds to your April 4, 1984 letter regarding the use of tw certification labels on motor vehicles, with each label containing a portion of the information specified in 49 CFR Part 567 and the two labels together providing all the specified information.; While the certification regulations specify that 'a label' shall b used, the agency has permitted the use of a label in two parts in circumstances which will not lead to confusion and which will satisfy the basic intent of Part 567. In particular, the two portions of the label must be placed in close proximity to each other, to permit individuals to readily find all the specified information and to leave no doubt as to the significance of either portion of the label. Further, the two portions must be oriented in such a manner that the information specified in section 567.4(g) of the certification regulations appears in the required order. As a practical matter, these considerations require that the two portions be affixed to the same vehicle part. While we cannot specify a particular distance as a maximum permissible separation of the two portions of the label, the two portions must be located so as to leave the unmistakable impression that they provide related information.; You also raised the possibility of adding language to one portion o the label to indicate the existence of the other portion and to specify the location of the second portion. While such language is not required, it might be a desirable means of promoting compliance with the considerations discussed above.; Sincerely, Frank Berndt, Chief Counsel