Interpretation ID: nht72-5.5

DATE: 01/27/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Chesapeake Marine Products

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of December 17, 1971, in which you raised a question concerning the motor vehicle certification regulations, 49 CFR Part 967. You asked whether it would be permissible for you, as a distributor of boat trailers who receives those trailers in unassembled form from their manufacturers, to have the trailers shipped to you without the labels attached, and attach the labels yourself as the vehicles are assembled and sold.

We consider the action you suggest to be permissible under the certification regulations, as long as the affixing of the labels with the manufacturer's name is done with the consent, and on behalf of, the manufacturer. In so doing, you would be acting essentially as the agent of the manufacturer, fulfilling his legal responsibility under the statute and regulations.