Interpretation ID: nht87-3.13

TYPE: INTERPRETATION-NHTSA

DATE: 10/15/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: American Suzuki Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Head, Administration Government Relations Department American Suzuki Motor Corporation P.O. Box 1100 3251 East Imperial Highway Brea, CA 92622-1100

Dear Mr. Petler:

This letter responds to your letter of June 12, 1987, stating that your company wishes to and the following additional language to the Part 567 certification label:

"This vehicle equipped for 800 lb./360kg payload. See owner's manual for additional information.

You further state your understanding that NHTSA has permitted manufacturers to put information on the certification label beyond what Part 567 requires. You include two samples (-A- and -a-) representing certification labels, showing alternative location s on the label for your statement. The sample you designate as -A- shows your statement just above the required vehicle identification number, and just below the statement that your vehicle complies with all applicable Federal motor vehicle safety standa rd. The sample you designate as -B- shows your statement just below all of the information 5567.4 requires a manufacturer to put on the certification label. You ask which sample the agency would find acceptable.

You are correct that the agency his permitted manufacturers to include information on the certification label beyond that which Part 567 requires. There NHTSA has acquiesced in this practice, the additional information appeared after that required under 5567.4(g). Sample B shows the placement of your additional statement after the required Part 567 information. NHTSA finds that Sample B is acceptable so long as your label otherwise complies with Part 567. Sincerely,

Erika Z. Jones Chief Counsel

Erika Z. Jones, Esq. Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Re: Part 561 - Request for Interpretation

Dear Ms. Jones:

On behalf of Suzuki Motor Co., Ltd., of Japan, we are requesting an interpretation of Part 567-Certification, 567.1, as it applies to the placement of additional wording in the form of a statement addressing vehicle payload on the vehicle certification l abel. The additional statement reads:

"This vehicle equipped for 800 lb./360kg payload.

See owner's manual for additional information."

I have attached a drawing showing the statement placed in two different locations as illustrated in samples A and B. Suzuki's preference is sample A with the added statement being placed between the vehicle conformity statement and the VIN. If sample A p lacement is not acceptable to NHTSA. Suzuki would use sample B placement with the added statement appearing below the vehicle type description.

It is our understanding that NHTSA has permitted the use of additional wording or information on certification labels in response to requests like ours from other manufacturers. Suzuki also believes the addition of payload information for this particular vehicle would be of value to the vehicle owner.

Thank you for your assistance in this matter. We look forward to your prompt response to our request for interpretation. Sincerely,

AMERICAN SUZUKI MOTOR CORPORATION

Frederick M. Petler Head, Administration Government Relations Department

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