Interpretation ID: 77-4.28

TYPE: INTERPRETATION-NHTSA

DATE: 11/04/77

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA

TO: Mr. Donald H. Carter

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letters of August 24, 1977, and October 8, 1977, concerning your Ford F-150 pickup truck.

The November 1976 date on your truck's certification label refers only to the date of actual manufacture of the vehicle, not its model year. Virtually all manufacturers, including Ford, utilize a model year which does not correspond to the calendar year. Typically, for American manufacturers, this model year begins on September 1 of the previous calendar year, i.e., model year 1977 began on September 1, 1976. Manufacturers usually begin manufacture of their vehicles as early as July in order to have sufficient vehicles in their showrooms by the September start of the model year.

All Federal motor vehicle safety standards specify a date on which their requirements become effective. Thus, the manufacturer must indicate by the certification label that its vehicles are in compliance with all Federal standards in effect on the date of the vehicles' manufacture. Whether a vehicle is marketed as a particular model year vehicle depends upon the manufacturer's own marketing practice. The certification date does not represent the model year date.

Finally, your first letter stated that your vehicle was ordered on November 4, 1976, with a 3 month delivery interval. Every manufacturer produces a large number of vehicles before there are orders for a specific vehicle, and maintains them in various storage locations around the country. When the manufacturer receives an order from a dealership for a specific vehicle, it will first determine whether it already has such a vehicle in stock, and if it does, it will ship that vehicle rather than specially manufacture a new vehicle.

However, if there is no identical vehicle in stock, it will manufacture one specifically for that order, which can take from a few days to several months to program into the assembly line and produce. As a dealership has no way to know in advance whether the vehicle it ordered is in stock or will have to be specially manufactured, it will often state a delivery date that anticipates the longest possible delay which would result from special manufacture. There is thus no reason for concern over the fact that your vehicle was manufactured in the same month it was ordered. Either Ford had such a vehicle in stock, or was able to manufacture one with very little delay.

I hope that this letter has answered your concerns.