Interpretation ID: nht88-3.81

TYPE: INTERPRETATION-NHTSA

DATE: 11/01/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: DAVE ANDERSON -- SALES MANAGER, GIST ORNAMENTAL IRON WORKS

ATTACHMT: NOT INCLUDED

TEXT: This responds to your letter about Federal requirements for trailers. According to your letter, you are in the planning stages of becoming a manufacturer of, and dealer for, automobile trailers. The trailers would hitch to the back of automobiles and b e designed to carry cargo. You noted that in response to an earlier inquiry, you received a copy of the handout entitled "Information For New Manufacturers of Motor Vehicles and Motor Vehicle Equipment." You stated that you are unclear just how this app lies to automobile trailers. You asked what you need to do to comply with any applicable Federal regulations, and what regulations apply to trailers of the kind you plan to build.

Trailers are considered motor vehicles under federal law. As a manufacturer of motor vehicles, you would be required to submit identification information to the National Highway Traffic Safety Administration (NHTSA) under 49 CFR Part 566, Manufacturer I dentification. You would also be required to certify that each trailer complies with all applicable Federal safety standards. The procedure is specified in 49 CFR Part 567.

The following safety standards apply to trailers: Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, Safety Standard No. 115, Vehicle Identification Number -- Basis Requirements, Safety Standard No. 119, New Pneumatic Tires for Vehicles Other Than Passenger Cars, Safety Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars. The content requirements for the vehicle identification number are found at 49 CFR Part 565. In addition, trailers with certain braking systems must meet Safety Standard No. 106

Brake Hoses, Safety Standard No. 116, Motor Vehicle Brake Fluids, and Safety Standard No. 121, Air Brake Systems. All of these safety standards are found in 49 CFR Part 571.

I hope this information is helpful.

ENCLOSURE