Interpretation ID: nht73-4.9

DATE: 04/11/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Hyland Manufacturing Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of March 30, 1973, in which you asked whether the date a vehicle is completed, with reference to the date of manufacture placed on the vehicle certification label, is the date a vehicle comes off the "main production line" or the date it comes out of the "final finish production area".

On this question we are willing, in light of the wide variety of possible factual situations, to let a manufacturer use his own discretion within reasonable limits. As you have described your situation, either date may be used, up to the point where the last physical operations are completed. The "final quality control checkout", however, would appear to be an operation taking place after the manufacture as we normally understand it is completed.