Interpretation ID: nht73-2.4

DATE: 01/24/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Chesapeake Marine Products

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of December 13, 1972, requesting information as to how a distributor who assembles a boat trailer may certify the trailer under NHTSA requirements, when the weight ratings for the trailer when assembled differ from those anticipated by the fabricator, due to the distributor's use of components (tires and springs) of a greater weight-carrying capability than those envisioned by the fabricator.

The certification requirements applicable to the manufacture of boat trailers are found at section 567.4, "Requirements for Manufacturers of Motor Vehicles". The fabricator may affix the required label to a trailer in certain cases (section 567.4(f) (ii); but in the case you describe, where the distributor assembles the vehicle in a manner not specifically anticipated by the fabricator, the assembler is the appropriate person, pursuant to @ 567.4(g)(1), to certify the vehicle and affix the certification label. The label should state the name of the assembler (the distributor) as the manufacturer and reflect the weight ratings of the vehicle as assembled.