Interpretation ID: nht73-3.18

DATE: 01/30/73

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Oshkosh Truck Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 4, 1973, in which you ask for our confirmation of your interpretation of Part 567 and Part 568 of Title 49 of the Code of Federal Regulations that would place the responsibility for certification on the user in those instances where he is the final-stage manufacturer.

Paragraph 567.5 of Title 49 of the Code of Federal Regulations Requirements for Manufacturers of Vehicles Manufactured in Two or More Stages, specifies that(Illegible Words) final-stage manufacturer, . . . of a vehicle manufactured in two or more stages shall affix to each vehicle a label . . . ." Therefore, and users who are also manufacturers would be required to affix the label.

If you have further questions, we will be pleased to answer them.