Interpretation ID: HYUNDAI.CRS

Mr. Robert Babcock
Manager, Government Affairs
Hyundai America Technical Center, Inc.
5075 Venture Drive
Ann Arbor, MI 48108

Dear Mr. Babcock:

This is in response to your letter of September 9, 1996, to Coleman Sachs of my staff, concerning an error in the certification labels placed on certain 1997 Hyundai Tiburons. As described in your letter, these labels contain a misspelling of the word "passenger," which appears as "passbnger" in the vehicle type classification that was inserted on the label under the vehicle certification regulations at 49 CFR 567.4(g)(7). You state that Hyundai implemented a running change to current production after it discovered this error, but that the company has no plans to institute a recall or other campaign to correct the error on vehicles already produced. The company has requested our comments if we do not agree with its decision in this matter.

Because the nature of the misspelling could cause no confusion with respect to the vehicle's classification, we agree that Hyundai is not obliged to correct the labels on vehicles already produced.

If you have any further questions concerning vehicle certification requirements, feel free to contact Mr. Sachs at 202-366-5238.

Sincerely,

John Womack

Acting Chief Counsel

ref:568

d:9/25/96