Interpretation ID: nht73-5.12

DATE: 09/25/73

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Crown Coach Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 28, 1973, concerning the effective date of Motor Vehicle Safety Standard No. 121. Your direct question is whether the effective date is the starting or completion date for the vehicle's components or the starting date for the vehicle.

Standard No. 121 applies to the vehicle and its effective date therefore relates to the vehicle, rather than to any of its components. A vehicle completed after the effective date will have to meet the standard, even though it is equipped with a foundation brake system that was manufactured before the effective date.

The vehicle's completion date, rather than its starting date, is the date that determines whether it must conform to the standard. If your company manufactures its vehicles from the ground up, rather than installing a body on a vehicle built by another manufacturer, the relevant completion date is the date you complete your manufacturing operation. However, if you buy an incomplete vehicle, as defined in our regulation on vehicles manufactured in two or more stages (49 CFR Part 568), and complete that vehicle, you may choose as the completion date for purposes of Standard No. 121 the date on which the manufacturer of the incomplete vehicle finished his work, the date on which you completed the vehicle or any date in between.

ENC.