Interpretation ID: nht72-1.34

DATE: 03/29/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Toyo Kogyo Detroit Office

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of March 16, 1972, in which you ask whether the definition of "unloaded vehicle weight" is the same as that for "'curb weight' plus optional parts," and whether the definition of "gross vehicle weight" is the same as that for "maximum loaded vehicle weight."

The two sets of definitions are expressed in substantially different terms. The new terms, "unloaded vehicle weight" and "gross vehicle weight rating" are more general than the older ones. The newer terms also eliminate some ambiguities in the definitions based on "curb weight," such as just what is (Illegible Word) by "standard equipment," and whether other vehicle fluids besides fuel, oil, and coolant should be included. Further, GVWR is a rating, not necessarily identical to any scale weight although some constraints have been placed on it in our Certification regulations (@ 567.4(g)(3)).

Thus, although the two sets of definitions are somewhat similar in their application, they are different enough that each must be interpreted and used in its own terms.