Interpretation ID: nht80-1.25

DATE: 03/05/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Bus Con Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your January 22, 1980, letter asking two questions about the use of your body conversion numbers on the certification labels of vehicles you produce.

First, you ask whether a final-stage manufacturer may substitute its body conversion number for the vehicle identification number (VIN) that comes with the incomplete vehicle. The answer to this question is no. The VIN must be continued from the incomplete vehicle certification label to the final-stage certification label. However, you may insert your body conversion number on the label in addition to the VIN. Your number should appear at the bottom of the label below the required information.

In your second question, you ask whether you may include your body conversion number on the alterers' labels for previously certified vehicles that you alter. The answer to this question is yes. As indicated above the number should appear at the bottom of the label below the required information.

Sincerely,

ATTACH.

BUS CON CORP

January 22, 1980

Chief Counsel -- U.S. Department of Transportation, National Highway Traffic Safety Administration

Dear Sir,

I am enclosing photostats of two certification labels mandated by Part 567. I would appreciate answers to the following questions.

1). On the label for vehicles manufactured in two or more stages, may we the final stage manufacturer, insert our body conversion number as the vehicle identification number? If not, where may we put our number?

2). On the label for persons who alter previously certified vehicles, may we put our body conversion number somewhere on this label. If so where on the label may we put it. If not can we put our number elsewhere.

I would appreciate a prompt reply to this letter so that I may get labels printed. If you have any questions, please contact me. My business card is enclosed.

Yours truly,

David Shomberg

Enc/

Label Requirements for Persons Who Alter Previously Certified Vehicles Effective: February 1, 1974 *

* Tire sizes can be listed. 567.4(h)

Individual or corporate name

Month and year in which alterations were completed (May be abbreviated 2/74)

No earlier than the manufacturing date of the original vehicle nor later than the date alterations were completed

Use if different from the original

Use if alterations change vehicle type

THIS VEHICLE WAS ALTERED BY THE FINE CAR CO., INC. IN FEBRUARY 1974

AND AS ALTERED IT CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS IN EFFECT IN JANUARY 1974

*GVWR 0000

*GAWR FRONT 0000 REAR 0000

TYPE BUS

Can I put our Body Conversion Number on this label?

Label Requirements for Vehicles Manufactured in Two or More Stages On or After: January 1, 1972 *

* Tire sizes can be listed. 567.4(h)

See text of the regulation for alternatives for final stage manufacturers who complete chassis-cabs.

May be abbreviated MFD Full corporate name

Month and year of manufacture (May be abbreviated 7/72)

Name of original manufacture of incomplete vehicle (May be abbreviated "INC. VEH. MFD. BY")

Gross Vehicle Weight Rating (GVWR) Gross Axle Weight Rating (GAWR)

Use exact text specified in Regulations No earlier than the manufacturing date of incomplete vehicle nor later than the date of completion

Vehicle Identification Number

Type vehicle

MANUFACTURED BY THE FINE CAR CO., INC. JULY 1972

INCOMPLETE VEHICLE MANUFACTURED BY

CLASSIC TRUCKS INC.

JANUARY 1972

GVWR 0000

GAWR FRONT 0000 REAR 0000

THIS VEHICLE CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS IN EFFECT IN MARCH 1972

0000 TRUCK

NOTE: When preparing labels, all characters must be 3/32" or more in height in block capitals and numerals and printed in a color in contrast to the background. See text of the regulation for labeling requirements for intermediate manufacturers.

Can I put our Body 10 Conversion Number where circled or must the number there be the one assigned by the chassis manufacturer?