Interpretation ID: aiam1344
Truck Equipment & Body
602 Main Street
Cincinnati
OH 45202;
Dear Mr. Pieratt: This is in reply to your letter of November 6, 1973, requestin information on whether vehicle certification labels must be affixed by persons who for their own use install fifth wheels on chassis cabs.; The NHTSA takes the position that vehicles completed by persons fo their own use must conform to all applicable motor vehicle safety standards and be certified (by affixing the appropriate label) as conforming. The NHTSA considers the use of these vehicles to be an introduction or delivery for introduction in interstate commerce and subject to the prohibitions of section 108 of the Safety Act. Persons who complete incomplete vehicles are final-stage manufacturers and all other regulations applicable to manufacturers (Parts 566, 573, and 577) apply to them.; Yours truly, Richard B. Dyson, Assistant Chief Counsel