Interpretation ID: certlab3.crs
Professional Micro Computer Service, Inc.
2525 Honolulu Avenue
Montrose, CA 91020
Dear Ms. Mor:
This is in response to the memorandum of July 29, 1997 that you telefaxed to Coleman Sachs of my staff, forwarding for our review a format for a vehicle certification label (which you refer to as a "VIN label") that your company is proposing to offer to clients who manufacture trailers for sale in both the United States and Canada. Your memo requested that we disregard your letter of July 15, 1997, forwarding for our review an earlier version of the certification label format that you withdrew after speaking to David Coleman of our Office of Vehicle Safety Compliance.
Certification requirements for vehicles manufactured for sale in the United States are set forth in this agency's regulations at 49 CFR Part 567. Section 567.4 of those regulations specifies the contents and format of the certification label that manufacturers are required to affix to new motor vehicles to which one or more of the Federal motor vehicle safety standards apply. To meet those requirements, the following modifications would have to be made to the certification label format that your company has most recently proposed:
- Section 567.4(g)(2) requires the certification label to specify the vehicle's "month and year of manufacture." The first line of your company's label format contains the word "date" followed by a colon. We recommend that this heading be changed to "date of manufacture" or "manufactured in" to better identify the date provided.
- Section 567.4(g)(3) specifies that the certification label must include the vehicle's gross vehicle weight rating, or "GVWR," "followed by the appropriate value in pounds . . . ." The second line of your company's label format contains the letters "GVWR/PNBV" followed by the abbreviation "KG," which presumably represents "kilograms." To comply with section 567.4(g)(3), the GVWR value must be specified in pounds. If you wish to provide a metric equivalent for this value, it should be specified in kilograms, with that word fully spelled out, followed by the corresponding value in pounds, appearing in parentheses. With this format, the entry for GVWR/PNBV would be as follows:
GVWR/PNBV: ________ kilograms (________ pounds)
- Section 567.4(g)(4) specifies that the certification label must include the gross axle weight rating, or "GAWR," "followed by the appropriate value in pounds for each axle, identified in order from front to rear . . . ." The third line of your company's label format contains the letters "GAWR/PNBE," followed by the abbreviation "KG." To comply with section 567.4(g)(4), the GAWR of each axle should be specified in pounds. If you wish to provide a metric equivalent for this value, it should be specified in kilograms, with that word fully spelled out, followed by the corresponding value in pounds, appearing in parentheses, as set forth in the above format for GVWR/PNBV entries.
We note that your company's proposed label format also includes information on the size designation for tires and rims and the recommended cold inflation pressure for tires that is required under Federal Motor Vehicle Safety Standard No. 120, Tire Selection and Rims for Motor Vehicles other than Passenger Cars, as found at 49 CFR 571.120. Paragraph S5.3 of that standard requires the cold inflation pressure to be identified first in metric units (kPa) and then in English units (psi). On your company's proposed certification label, English units are listed before metric units under the heading "COLD INFL PRESS." To comply with paragraph S5.3 of Standard No. 120, this order of presentation should be reversed.
I hope this information is helpful. If you have any further questions regarding vehicle certification requirements, do not hesitate to contact Mr. Sachs at 202-366-5238.
Sincerely,
John Womack
Acting Chief Counsel
ref:567
d.7/31/97