Interpretation ID: aiam1759
General Manager
VDO Instruments
116 Victor Avenue
Detroit
Michigan 48203;
Dear Mr. von Payr: This is in reply to your letter of December 26, 1974 asking question about Motor Vehicle Safety Standard No. 123, *Motorcycle Controls and Displays*.; Standard No. 123 applies to motorcycles, and the manufacturer of th completed vehicle is responsible for compliance with the standard. The standard does not include items manufactured for the aftermarket. Under an amendment to the National Traffic and Motor Vehicle Safety Act of 1966 that became effective late in December 1974 a dealer may not 'render inoperative', *e.g.* remove, equipment installed by the manufacturer that has been installed in compliance with a standard. There would be no objection, however, if a dealer removed an originally installed speedometer and replaced it with one that also met the Federal requirements.; The date of applicability of a standard is the date the vehicle wa manufactured, not the date it is sold. Therefore non-complying motorcycles manufactured before the effective date of Standard No. 123 - September 1, 1974 - may be sold after that date. The standard applies to those motorcycles manufactured primarily for use on the public roads, and not to mini-bikes, trail bikes, ATVs, or other non-licensed vehicles intended for off-road use.; Standard No. 123 does not require a specific size for numerals, onl that 'Major graduations and numerals appear at 10 mph intervals, minor graduations of the 5 mph intervals' (Column 3, Table 3). With respect to your paragraphs a) and b) on page 3 of your letter, elimination of any speed indication at the required 10 mph intervals would result in a noncompliance of the cycle on which the speedometer was mounted. Since your enduro and chopper speedometers are marked only at 20 mph intervals they do not meet the requirements of Standard No. 123 for original motorcycle equipment.; Yours truly, Richard B. Dyson, Acting Chief Counsel