Interpretation ID: nht69-1.44

DATE: 08/13/69

FROM: AUTHOR UNAVAILABLE; Dowell H. Anders; NHTSA

TO: Great Dame Trailers Incorporated

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of August 4, 1969, in which you asked whether the name of your company may be placed on the certification label affixed to vehicles manufactured by another company.

The question of "private brand" manufacturing was raised at various stages of rulemaking in respect to the certification regulations. It was decided that the certification label on a vehicle must show the name of the actual manufacturer. This information is important in the enforcement of standards and regulations under the Act. The Vehicle Safety Act, moreover, places primary responsibility for conformity to the standards, and for certification of conformity, on the manufacturer, and the regulations are designed to implement that intent. You should note, however, that as a distributor of the vehicles in question you share the responsibility for compliance with the standards to the extent of your knowledge, and participate in the certification by passing it along to dealers or other distributors.

We are pleased to be of assistance.