Interpretation ID: nht72-4.41

DATE: 09/01/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Intercontinental Equipment Corp.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of July 27, 1972, in which you raise several questions concerning Part 566, Manufacturer Identification, Part 567, Certification, and Part 568, Vehicles Manufactured in Two or More Stages. You state that Intercontinental Equipment Corp. (I.E.C.) is the United States importer and distributer of certain vehicles manufactured by Suzuki Motor Co., Ltd. in Japan. You also state that I.E.C. has contracted with Yachiyoda Sangyo Co., Ltd. of Tokyo to acquire vehicles from Suzuki, remove non-complying equipment, install approved devices, and affix necessary labels of conformity and arrange for shipment.

The answers to your questions are as follows:

1. You ask whether the I.E.C. contract with Yachiyoda changes the status of Suzuki as manufacturer and I.E.C. as importer. It does not change the status with respect to our manufacturer identification and certification regulations.

2. You inquire as to the classification of Suzuki and Yachiyoda under Part 568, Vehicles Manufactured in Two or More Stages. Since Suzuki manufactures a completed vehicle, Yachiyoda is not considered a manufacturer under NHTSA regulations and is not required by the NHTSA to submit manufacturer identification or certification information.

3. You ask whether the label of conformity (Label #2) which you propose to have affixed to the vehicles is acceptable. The NHTSA finds it acceptable.

I enclose copies of Parts 566, 567, and 568 for your information.