Interpretation ID: nht72-2.10

DATE: 03/14/72

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Hance; Caston; Hefner and Green

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 25, 1972, concerning the certification of new trailers which your client manufactures. You state that some of those trailers are shipped (to customers) equipped with used tires that are intended primarily to be used to ship the trailers to their destination, and ask whether these tires should be taken into account in the values for GVWR and GAWR on the certification label.

We do not consider that temporary tires attached to a vehicle for purposes of shipment should be refelcted in the GVWR and GAWR on the certification label, if these tires are not intended to be part of the completed vehicle. Consequently, we would expect trailers certification as vehicles for which no tires have been provided. In such a case, the complete vehicle manufacturer, as indicated in the preamble to the Certification regulations (April 14, 1971, 36 F.R. 2054) must still bear responsibility and certify the vehicle, even though he does not install the tires with which the vehicle will ultimately be equipped. We suggest that one manner in which this could be accomplished by the manufacturer is to list GAWR and GVWR for the optional tire sizes which he recommends in accordance with the amendment to the Certification regulations published December 10, 1971 (35 F.R. 23571). The manufacturer should make it clear to the purchaser of the vehicle that the temporary tires should be replaced when the vehicle is put into use.

We are pleased to be of assistance.