Interpretation ID: nht71-4.20

DATE: 10/14/71

FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA

TO: Forse Cleanamation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 29, 1971, to Mr. J. E. Leysath of this Office requesting information relative to the lighting requirements applicable to your E - Z Tow towing unit.

The E-Z Tow unit is a "motor vehicle" as defined by the National Traffic and Motor Vehicle Safety Act of 1966 since it is a "vehicle . . . drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways." However, since it is designed to "tow" rather than to "carry" property, the E-Z Tow unit is not a "trailer" as defined for purposes of the Federal Motor Vehicle Safety Standards. Since it is an unclassified "motor vehicle," the lighting requirements of Federal Motor Vehicle Safety Standard No. 108 are not applicable; therefore, you need only to comply with the lighting requirements of the States in which you sell or use the unit.