Interpretation ID: nht72-5.21

DATE: 03/24/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Truck Equipment & Body Distributors Association

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of March 6, 1972, concerning the certification of pickup trucks that are modified while still in the hands of a dealer. You describe a situation in which the dealer removes the pickup body and sends the vehicle to a final-stage manufacturer for fitting with a service body.

We would consider modifications of the type you describe to be manufacturing under the National Traffic and Motor Vehicle Safety Act, and the Certification regulations (49 CFR Part 567). Because a completed vehicle is involved regulations governing Vehicles Manufactured in Two or More Stages (Part 568) do not apply.

One who remanufactures a completed vehicle assumes the responsibility of any manufacturer of completed vehicles. The extent to which he may safely rely on the original GVWR, GAWR, and statement of conformity depends on what he has done to alter the vehicle. He is required to certify the vehicle by affixing his own label, and must take into account the effects of any modifications he makes.