Interpretation ID: nht88-4.11

TYPE: INTERPRETATION-NHTSA

DATE: 11/16/88

FROM: TERRY HUDYMA -- LAFORZA AUTOMIBILES INC

TO: CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION U.S. DEPARTMENT OF TRANSPORTATION

TITLE: 49CFR 567, CERTIFICATION

ATTACHMT: ATTACHED TO LETTER DATED 09/07/89 FROM STEPHEN P. WOOD -- NHTSA TO TERRY HUDYMA -- LAFORZA AUTOMOBILES; REDBOOK A34 B; PART 567; PART 568; LETTER DATED 05/06/85 FROM JOFFREY R. MILLER CHIEF COUNSEL TO HAYLEY ALEXANDER

TEXT: Dear Sirs:

LAFORZA Automobiles (formerly Rayton Fissore North America) has acquired the US rights to manufacture and sell a MPV designed and manufactured by Rayton Fissore of Cherasco, Italy. LAFORZA Automobiles is incorporated in the state of California.

The vehicle will be built in two stages. Pininfarina will build the vehicle complete with everything except the engine (and associated equipment such as ignition and air conditioning, etc.) transmission and transfer case in Italy. These items along with some of the lighting fixtures will be installed by Cars and Concepts in Brighton, Michigan to complete the vehicle. These operations both will be performed by the respective firms under contract to LAFORZA Automobiles. Thus LAFORZA Automobiles will ha ve complete control of the manufacturing process at all times.

It is our understanding that under these circumstances, LAFORZA Automobiles is considered to be the manufacturer of the vehicle. They therefore must apply the certification label required under 49CFR Part 567, Certification, upon completion of the vehic le at Cars and Concepts Inc.

Please provide us with a verification of our interpretation of this matter with a copy to our Safety Consultant, Haus W. Metzger, 6323 E. Turquoise Ave., Scottsdale, Arizona 85253.

We would appreciate a prompt reply. Thank you for your coorperation in this matter.

Yours truly