Interpretation ID: aiam1745
Attorney
Volkswagen of America
Inc.
Englewood Cliffs
New Jersey 07632;
Dear Mr. Reichel: This is in reply to your letter of December 4, 1974, to Michael Pesko of this office asking whether it is permissible under Standard No. 110 to refer to air conditioning and automatic transmission option in stating the 'vehicle capacity weight' on the placard required under S4.3 of the standard. The format you suggest would state a vehicle capacity weight, followed on a separate line by the statement: 'If air conditioning is installed, subtract 82 pounds.' you also ask whether basic vehicle body style may be similarly treated. Your request is based on your desire to standardize the placard required by Standard No. 110, to make the placarding requirements less expensive to meet.; We interpret Standard No. 110 to permit the use of a standardize placard that contains various vehicle capacity weights based on body style or the presence of various options. However, in such a case we believe that label should at least initially contain the lowest vehicle capacity weight for the vehicle, that is, a weight which presumes that the vehicle is equipped with those options having an effect on vehicle capacity weight. If the absence of these options increases the vehicle capacity weight, we believe this should be stated beneath the basic vehicle capacity weight, and by specifying the actual weight with the option omitted rather than asking the reader to perform a computation.; Yours truly, Richard B. Dyson, Acting Chief Counsel