Interpretation ID: nht72-5.41

DATE: 07/19/72

FROM: CHARLES H. HARTMAN FOR DOUGLAS W. TOMS -- NHTSA

TO: Stutz Motor Car of America Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of June 21, 1972. As I understand it, your company purchases Pontiac Grand Prix models for conversion into vehicles bearing the Stutz nameplate. Your converter, however, has a number of vehicles in stock, the majority of which will not be converted until after September 1, 1972. You ask, in effect, that we require compliance only with those Federal standards in effect on the date of manufacture of the original Pontiac Grand Prix, and that we do not require compliance with standards which may have come into effect after that time and before completion of the State conversion.

The information contained in your letter indicates that the changes you make to the Grand Prix are confined to cosmetic changes such as alteration of the exterior sheet metal, reupholstering the interior, and replacement of the back light with glazing conforming to Standard No. 205. If the converted Grand Prix conforms to those Federal motor vehicle safety standards for which temporary exemptions was granted State (Standards Nos. 104, 201, 205, 210 and 212), we will consider it permissible for General Motors to continue to be the "manufacturer" of the vehicle for certification purposes. In that case, the date of manufacture is considered to be the date of completion by General Motors, and the original certification label should be retained on the car when converted.

The vehicle must nevertheless conform at the time of sale to all safety standards and other regulations (for example, 49 CFR Part 575, Consumer Information) that are applicable on its date of manufacture.