Interpretation ID: nht72-5.38

DATE: 03/20/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Robert Waggoner

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of February 16, 1972, requesting information on "a new law effective January 1, 1972, that makes it mandatory that manufacturers of truck bodies and those repairing such items must now certify their product."

The National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 et seq.) has required since January 1, 1968, that manufacturers of motor vehicles and motor vehicle equipment certify that the products they manufacture comply with all applicable Federal motor vehicle safety standards (49 CFR 571.101 et seq.). The "new law" to which you refer is actually regulations issued pursuant to Section 114 of the Act (15 U.S.C. 1403) which amended existing regulations specifying the method by which manufacturers are to certify compliance. These regulations are the Certification regulations (49 CFR Part 567) and the regulations governing "Vehicles Manufactured in Two or More Stages" (49 CFR Part 568). I have enclosed copies of both for your information.

These regulations apply to manufacturers and distributors of motor vehicles as defined in the regulations. They only apply to manufacturers of truck bodies if such manufacturers install the truck bodies on chassis, thus completing the vehicles. The regulations do not apply to one who only repairs truck bodies.