Interpretation ID: nht69-2.50

DATE: 09/25/69

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Bennett's Truck Equipment

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of September 10, 1969, in which you asked whether you should certify the trucks that you assemble as a manufacturer or a distributor, and what are the safety standards to which your vehicles must comply.

The answer to your first question is that if you assemble the body to the chassis, you must certify as a manufacturer, regardless of by whom the body or chassis is fabricated. You should note that under the "chassis-cab ruling" (pages 43 and 369 of the enclosed regulations) the chassis-cab manufacturer is required to certify on a temporary label as to the standards to which the chassis-cab will comply when completed.

In response to your second question, I am enclosing a copy of the motor vehicle standards and regulations.