Interpretation ID: nht94-8.14

DATE: February 14, 1994

FROM: Daniel T. Mason -- Product Development Engineer, Automotive Division, Avery Dennison

TO: Barbara Gray -- Office of Market Incentives, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4/8/94 from John Womack to Daniel T. Mason (A42; Part 541)

TEXT:

The purpose of this letter is to ask for a ruling of the footprint requirements of the parts marking legislation, 541-Federal Motor Vehicle Theft Prevention Standard.

I am a Product Development Engineer working under Cliff Nastas for Avery Dennison. My question refers to the footprint feature of the label that appears under a UV light in the substrate after the label (illegible words).

Both Avery Dennison and (illegible word) supply parts marking labels to the automotive industry. Both have a florescent agent that migrates into the substrate once applied. Would a label that substitutes a florescent copy of the VIN instead of the whole footprint of the label be in compliance to the federal legislation?

Please inquire for a ruling on this. I will follow up this letter with a phone call to discuss any questions you may have in the next couple weeks.