Interpretation ID: nht94-4.39

TYPE: INTERPRETATION-NHTSA

DATE: September 29, 1994

FROM: Alberto Negro -- Chief Executive Officer, Fiat Auto R&D U.S.A

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: 49 CFR Part 583 - Automobile Parts Content Labeling Request for Interpretation

ATTACHMT: ATTACHED TO 3/14/95 LETTER FROM PHILIP R. RECHT TO ALBERTO NEGRO (PART 583; REDBOOK (2))

TEXT: I am writing to ask that you verify whether the 1000 unit threshold of 49 CFR 583.5(g) applies to the Alfa Romeo and Ferrari marques separately or collectively, as those marques are both owned by Fiat S.p.A. Fiat S.p.A. is the stockholder of Fiat Auto S. p.A., which produces Alfa Romeo cars, and of Ferrari S.p.A. which produces Ferrari cars.

I thank you for your consideration and I remain at your disposal for all additional information that you require.