Interpretation ID: nht73-4.13

DATE: 04/30/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Anderson-Alford

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of April 3, 1973, inquiring whether there are licenses and forms that you must obtain before you may install old truck bodies on new trucks.

Persons who install used truck bodies on new trucks are generally considered to be "final-stage manufacturers" under NHTSA Certification regulations (49 CFR 567, 568). These regulations require final-stage manufacturers of multi-stage vehicles to certify the conformity of such vehicles to all applicable motor vehicle safety standards. Certification is accomplished by affixing a label to the vehicle. The requirements for both the location and content of the label are contained in the Certification regulations, and you may obtain copies of these regulations as indicated or the enclosed. "Where to Obtain Motor Vehicle Safety Standards and Regulations".

There are no licensing requirements, nor specified forms you must complete before you undertake these manufacturing operations. However, the NHTSA does have requirements, (Part 566, "Manufacturer Identification", copy enclosed) that company within 30 days after commencing manufacture.