Interpretation ID: aiam0432
Esq.
Room 2000
100 W. Monroe Street
Chicago
IL 60603;
Dear Mr. Levin: This is in reply to your letter of July 23, 1971, concerning certai aspects of Motor Vehicle Safety Standard No. 205, 'Glazing Materials.'; You are correct in your statement that Standard No. 205, which has bee in effect since January 1, 1968, and was amended on September 19, 1968 (33 F.R. 14163) and March 1, 1969 (34 F.R. 3688), applies to a manufacturer of automobile sunroofs, 'either in kits for installation by others, or for direct installation by the sunroof manufacturer, in either case after the car has been completed.' To comply with the standard the sunroof material must meet the requirements for either AS1, AS2, AS3, AS4, AS5, AS10, or AS11 glazing material, as specified in ANSI Standard (formerly ASA Standard) Z26.1-1966, July 15, 1966. The 1969 amendment to this standard has not, as you state, been incorporated into Standard No. 205. However, a notice of proposed rulemaking published January 9, 1971 (36 F.R. 326), proposed to include that amendment. This matter is presently under consideration.; You are also correct in stating that a sunroof is an item of moto vehicle equipment, and not a motor vehicle. Certification may be made, pursuant to section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403), by the statement you submit, 'Material Certified to Comply with U.S. Motor Vehicle Safety Standard No. 205', followed by the name of the manufacturer.; We are pleased to be of assistance. Lawrence R. Schneider, Acting Chief Counsel