Interpretation ID: nht78-1.46

DATE: 12/05/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Mack Trucks, Inc.

TITLE: FMVSR INTERPRETATION

TEXT:

December 5, 1978 NOA-30

Mr. T. F. Brown Mack Trucks, Inc. P.O. Box 1761 Allentown, Pennsylvania 18105

Dear Mr. Brown:

This responds to your October 10, 1978, letter asking whether you are permitted to mark the certification documents of some of your incomplete vehicles as MACK TRUCKS, INC./RVI. These incomplete vehicles will be manufactured abroad by Renault Vehicules Industriels and imported into the United States by Mack Trucks, Inc.

Part 568, Vehicles Manufactured in Two or More Stages, requires an incomplete vehicle manufacturer to furnish with the incomplete vehicle certification its name and mailing address. Section 102(5) of the National Traffic and Motor Vehicle Safety Act states that the term manufacturer includes any person importing motor vehicles or motor vehicle equipment. Since your company will be importing these incomplete vehicles and an importer may be considered a manufacturer, it is permissible for you to label incomplete vehicles assembled by Renault with the MACK TRUCKS, INC./RVI designation.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

October 10, 1978

Ms. Joan Claybrook, Administrator National Highway Traffic Safety Administration U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Ms. Claybrook:

SUBJECT: Vehicle Certification MACK TRUCKS, INC./RVI

Mack Trucks, Inc. and Renault Vehicules Industriels (RVI) are negotiating an agreement whereby Mack would market Saviem trucks in the United States and Canada under the Mack name. Our current plan is to have the vehicles manufactured by RVI with the "MACK" letters on the front of the cab and shipped to the U.S. After their arrival at a U.S. port, the vehicles will be shipped to Mack branches and distributors throughout the U.S. and Canada. Mack Trucks will not perform any manufacturing operations on these vehicles.

It is our desire to furnish all certification documents with "MACK TRUCKS, INC./RVI" listed as the incomplete vehicle manufacturer. The incomplete manufacturer's address, when required, would be listed as:

MACK TRUCKS, INC./RVI Box M Allentown, Pa. 18105

We would appreciate your comments on this proposed practice.

Very truly yours,

MACK TRUCKS, INC.

T. F. Brown Executive Engineer Vehicle Regulations and Standards

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