Interpretation ID: nht80-2.39

DATE: 05/29/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: John Evans Mfg. Co.

TITLE: FMVSR INTERPRETATION

TEXT:

MAY 29 1980

Mr. Tom Spencer John Evans Mfg. Co. P.O. Box 669 Sumter, South Carolina 29150

Dear Mr. Spencer:

This responds to your May 6, 1980, telephone conversation with Roger Tilton of my staff in which you asked about the certification responsibilities for an incomplete trailer manufacturer. You indicated in your conversation that you manufacture chassis for trailers and supply them to finalstage manufacturers who complete them by the addition of a body. In particular, you asked whether you are required to comply with the provisions of Part 568.4, Vehicles Manufactured in Two or More Stages.

Part 568 places certain certification responsibilities upon incomplete vehicle manufacturers. The term "incomplete vehicle" is defined in section 568.3, as an assemblage including, at a minimum, the frame, chassis structure, power train, steering system, suspension and braking system to the extent that these systems are to be part of the completed vehicle. If a chassis that you manufacture is completed to the extent that it has the above-listed components and merely needs the addition of a body by a final-stage manufacturer, it would be considered an incomplete vehicle and would be required to comply with the incomplete vehicle document requirements of Part 568. Please note that your incomplete trailer need not have all of the components listed above to be considered an incomplete vehicle subject to Part 558. It need only have those components in the list that will be found in the completed vehicle. Since your trailer is an incomplete vehicle but not a chassis-cab as that term is defined in Part 567, Certification, it would not be required to have a chassis-cab manufacturer's certification label attached to it.

Sincerely,

Frank Berndt Chief Counsel