Interpretation ID: aiam0905
1414 Home Savings Building
1006 Grand Avenue
Kansas City
MO 64106;
Dear Mr. Burgess: This is in reply to your request of November 8, 1972, for informatio concerning the effects of governmental regulation on a decorative bumper that your client proposes to manufacture for sale in the automotive 'after-market.'; As far as Federal standards are concerned, your client's product is no a regulated item of equipment as long as it is installed after the vehicle has been sold to a customer for purposes other than resale. Although we have issued a standard to regulate the safety of bumpers on passenger cars (Federal Motor Vehicle Safety Standard No. 215, 49 CFR 571.215, effective September 1, 1972), the standard does not apply to the bumper as a separate item of equipment. Thus, a new car manufactured after the effective date of the standard must conform to the standard, but a bumper manufactured after the effective date and sold separately from the vehicle as a replacement part or add on, does not have to conform.; We strongly recommend, however, that any bumper system developed fo sale in the after-market be designed to conform to the performance requirements of Standard No. 215. If it should happen that significant problems are caused by the sale of inadequate bumpers, it may be necessary to expand the application of the standard to regulate the bumper as a separate item of equipment.; For your added information, state statutes with which we are familia also apply to new vehicles and would presumably not affect the installation of your client's product. However, you might find it advisable to ask the opinion of responsible state officials on this question.; If we can be of further assistance, please let us know. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;