Interpretation ID: aiam1193
Hank Thorp Inc.
Post Office Box 201. Edison
New Jersey 08817;
Dear Mr. Thorp: This is in response to your letter of July 7, 1973, which asks if th Manufacturer Code proposal (38 FR 14968, June 7, 1973) as it applies to wheel nuts (1) requires all manufacturers, including vehicle manufacturers, to label their products, (2) permits labeling with self-adhesive stickers, and (3) has authorized the issuance of codes at this time. In addition, you requested a clarification of an interpretation of Standard 211, *Wheel nuts*.; The answer to your first question is yes. The labeling requirement apply to foreign and domestic manufacturers of passenger cars and multi-purpose passenger vehicles and to manufacturers of equipment for those vehicles. The term 'manufacturer' includes an importer of vehicles or regulated equipment.; The use of a self-adhesive sticker in satisfaction of the permanent an legible labeling requirement of the proposal is permissible , so long as the information printed thereon is indelible and the label is affixed in such a manner that it cannot be removed without destroying or defacing it.; No codes have been assigned at this time. Assignment will not occu until a decision is reached as to issuance of a final rule.; The small hexagonal nuts which you import and which you describe a serving the same purpose as the small hexagonal nuts which secure factory-mounted, steel wheels to an axle, are not wheel nuts under the standard. The reference to normal coverage by a hub cap or wheel disc is simply descriptive of their location.; Yours truly, Richard B. Dyson, Assistant Chief Counsel