Interpretation ID: nht94-3.58

TYPE: INTERPRETATION-NHTSA

DATE: July 5, 1994

FROM: Michael Winzkowski -- CEO / Managing Director, Farmont Sunroofs Ltd., Odessa, FL

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: Re: DOT Code 205 Manufacturer Certification

ATTACHMT: Attached to 9/21/94 letter from John Womack to Michael Winzkowski (A42; STD. 205)

TEXT: We are a US-based subsidiary of a german automotive sunroof manufacturer with a associated glass plant which produces the glass panels for our sunroofs. A number of years ago we have obtained a DOT number for our glass panels, used in the USA. Due to t he fact that the German TUV is certifying and testing such glass panels and the US-DOT is relying on manufacturer self certification, we sometimes have the problem to convey the certification differences between the two countries to the German Authoritie s. The DOT numbers which appear on the glass panels of our product are simply proof of the fact that the manufacturer has obtained a registered number with the US-DOT after complying with the applicable self certification procedures without having to go through a test by your Department similar to the test administered by the German Government Authorities. It would be of great help if you could provide us with a formal letter, citing the applicable procedures for manufacturers regulated by vehicle gla zing code 205 to identify that in fact no US-DOT testing or certification is conducted when DOT numbers are assigned to manufacturers. An attached copy of the latest edition of DOT Code 205 (Vehicle Glazing Code) would be most appreciated.

Our glass manufacturer is FABA Autoglas Produktion in Germany. Farmont Sunroofs Ltd. in Florida is the assigned agent in the US. Our current master DOT number is DOT 500 (followed by manufacturers glass type and model code). I would appreciate to rece ive a letter from your office addressed to FABA Autoglas Produktion c/o Farmont Sunroofs Ltd. (my attention).

Should you have any further question please call me at any time. Thank you very much for your help.