Interpretation ID: nht75-2.29

DATE: 10/01/75

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of September 17, 1975, in which you ask whether a permanent label affixed to the inside surface of a hubcap would satisfy the requirements of a new proposed paragraph S3.2 of Standard No. 211.

The intent of the proposed labeling requirements, part of a general identification scheme for motor vehicle equipment manufacturers, is to ensure rapid and efficient identification of the manufacturer of a defective or nonconforming part or vehicle. The placement of an identifying label on the inside of a hubcap would not hinder rapid identification of the manufacturer. Therefore, the National Highway Traffic Safety Administration would consider that a label that is permanently affixed to the inside surface of a hubcap and contains the information specified in proposed paragraph S3.2 of Standard No. 211 would comply with the requirements of S3.2.

We hope this answer is satisfactory. If you have any other questions, please contact us.

YOURS TRULY,

September 16, 1975

Frank Berndt Chief Council National Highway Traffic Safety Administration

Re: Interpretation of Proposed Rule FMVSS 211

This is to ask for your interpretation of FMVSS 211, S.3.2 which was proposed in Docket No. 73-14; Notice 3, published on March 19, 1975.

S.3.2 (labeling requirement) states, "Each wheel nut, wheel disc and hubcap shall be permanently and legibly marked or labeled with . . . . .".

As the location of the mark or the label is not specifically mentioned in S.3.2, may we understand that it is in compliance with S.3.2 to affix permanently and legible the label on the inside surface of the hubcap?

Thank you for your attention to the above question. We look forward to hearing your interpretation of the above.

NISSAN MOTOR CO., LTD.

Tokio Iinuma

Staff, Safety