Search Interpretations

Interpretation ID: nht75-3.20

DATE: 07/18/75

FROM: AUTHOR UNAVAILABLE; James C. Schultz; NHTSA

TO: Chrysler Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of June 11, 1975, requesting an interpretation of Part 567 with respect to whether or not Chrysler should affix a certification label to an incomplete vehicle prior to shipping the vehicle to an outside vendor for body work.

It appears from your letter that there is some misunderstanding regarding the certification requirements applicable to manufacturers of incomplete vehicles. Section 567.4, to which you refer in your letter, is not applicable to vehicles manufactured in two or more stages. However, Section 567.5(c) provides that if an incomplete vehicle manufacturer assumes legal responsibility for all duties and liabilities imposed by the Act, as provided for in Section 568.7(a), then the incomplete vehicle manufacturer must ensure that a certification label is affixed to the final vehicle with the incomplete vehicle manufacturer's name after the words "MANUFACTURED BY" or "MFD BY". The data to be included on this label must follow the words "INCOMPLETE VEHICLE MANUFACTURED" or "INC VEH MFD" and is the "[month] and year in which the original manufacturer of the incomplete vehicles performed his last manufacturing operation on the incomplete vehicle . . . ." (Section 567.5 (a)(4)). The date as of which the manufacturer certifies that the vehicle conforms to applicable safety standards is any date no earlier than the manufacturing date of the incomplete vehicle and no later than the date of completion of final-stage manufacture. (Section 567.5(a)(7).

The regulations do not specify a date on which the certification label must be affixed. However Section 114 of the Traffic Safety Act provides that the label must be on the vehicle at the time of its delivery by the manufacturer to the distributor or dealer.

We trust that the above explanation will provide you with the guidance that you need. If you have any further questions, please let us know.