Interpretation ID: nht72-6.31

DATE: 06/29/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: All Brake & Drive Unit Service Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letters of February 14 and April 20, 1972. I apologize for our delay in answering your inquiries. You state that your G.M.C. truck dealership installs fifth wheels, saddle gas tanks, mirrors, marker lamps and tractor protection brake equipment and you inquire what your obligations are with respect to the Manufacturer Identification and Certification regulations (Parts 566 and 577 respectively).

Installation of fifth wheels would make you a "final-stage manufacturer", as defined in Part 568, Vehicles Manufactured in Two or More Stages, because you perform "such manufacturing operations on an incomplete vehicle that it becomes a completed vehicle", other than the addition of "readily attachable components, such as mirror or tire and rim assemblies". Installation of the other items you listed would generally not make you a final-stage manufacturer, since installation of these items does not fulfill the above criteria.

As a final-stage manufacturer, you are required under Part 566, Manufacturer Identification, to submit the information specified in @ 566.5. Your submittal of January 18, 1972, satisfies this requirement.

As a final-stage manufacturer, you are also required under Part 567, Certification, to affix a certification label on the vehicle you manufacture. In addition, Part 573 requires the submission of quarterly reports regarding vehicle production and defect notifications (49 CFR @ 573.5) and of copies of all other notices, bulletins and communications sent to more than one dealer or purchaser regarding any defect in such vehicles, whether or not safety-related.

I am enclosing copies of Parts 566, 567, 568, and 573 for your information. These should also answer your questions as to the format of the required submittals.