Interpretation ID: 19795.rbm
Ms. Kristin M. Werth
Weinberger & Kanan
Mile High Center, Suite 1910
1700 Broadway
Denver, CO 80290
Dear Ms. Werth:
This responds to your letter requesting an interpretation of Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection. Specifically, you asked for a description of how the date of manufacture is defined under the standard. You expressed particular concern about the parts of the standard that mandate the installation of air bags and warning labels.
For purposes of Standard No. 208, as well as the other Federal motor vehicle safety standards, the date of manufacture is the date on which the assembly and other manufacturing operations are completed for a motor vehicle. See 49 CFR Part 571.7 and 49 CFR Part 567.4(g)(2) and (5). Therefore, the "manufactured date" of a vehicle would typically be the production date at the vehicle manufacturer's factory.
The exception is a vehicle manufactured in two or more stages for which special provisions apply. "Incomplete vehicles" may be completed to the standards in effect on the date of manufacture of the incomplete vehicle, the date of final completion, or a date between those two dates. (1)
I hope the above information is responsive to your inquiry. Should you have any further questions or need any additional information regarding this matter, please feel free to contact
Ms. Rebecca MacPherson of my staff at this address or by telephone at (202)366-2992.
Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:208
d.4/17/2000
1. See 49 CFR sections 567 and 568. Note that section 568.6 specifies that this provision shall be superseded by any conflicting provisions of a standard that applies by its terms to vehicles manufactured in two or more stages. FMVSS No. 208 has no such provision.