Interpretation ID: nht74-3.44

DATE: 05/14/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Oshkosh Truck Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of March 27, 1974, in which you ask whether a final-stage manufacturer who mounts a used body on a new chassis is required to certify the conformity of the completed vehicle in accordance with 49 CFR Parts 567, 568.

The answer is yes. A person who mounts a used body on a new chassis is a final-stage manufacturer and is required to certify the conformity of the completed vehicle. The NHTSA has interpreted the Certification requirement as applying to any complete vehicle manufactured using a new incomplete vehicle (chassis) whether or not the body to be installed is new or used.