Interpretation ID: nht72-5.35

DATE: 09/28/72

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 August 31 and September 13, 1972, concerning certification of trailers and the addition of snow plows to completed vehicles.

In your letter of August 31 you asked how a final-stage manufacturer, or re-manufacturer, should verify a vehicle when as part of the work he performed he utilizes a used component. It is permissible for the manufacturer to certify the vehicle as if the component in question were new. You also ask for the status of a person who sells a trailer with what appears to be a kit by which the purchaser installs a section of the floor. We agree with your conclusion, assuming the floor is not "readily attachable", that such a manufacturer would be an incomplete vehicle manufacturer under Parts 567 and 568. He would consequently be required to furnish the purchaser with an "incomplete vehicle document" in accordance with Part 568, on which the purchaser can rely in completing and certifying the vehicle.

You are correct in the conclusion of your second letter that a person adding a snow plow to a completed vehicle (of which he is not the manufacturer) need not certify the vehicle, even if he must add auxiliary lights pursuant to Motor Vehicle Safety Standard No. 106. Such a person is not a complete or incomplete vehicle manufacturer, and need not report production figures pursuant to Part 573, Defect Reports.