Interpretation ID: nht80-1.40

DATE: 03/24/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: O'Meara Ford Center

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your February 26, 1980, letter asking about the proper certification for a Ford Mustang that has been converted to a convertible. You ask what certification is required before you would be permitted to sell such a vehicle.

The National Highway Traffic Safety Administration requires all manufacturers of motor vehicles to certify that their vehicles comply with Federal safety standards prior to first sale. In the case of the vehicle that you mention, Ford Motor Company would have certified it when it was sold to the company that converted it to a convertible. Ford's certification label is located on the driver's door or pillar post.

The company that converted the vehicle, Tomaso of America, is responsible for putting its own label on the vehicle indicating that as altered the vehicle continues to comply with the applicable Federal safety standards. The requirements for alterers' labels are located in Title 49 of the Code of Federal Regulations, Section 567.7. Tomaso's label should also be located on the vehicle in the same area as Ford's.

If both of the labels are on the vehicle, it is legal for you to sell it. If either of the labels is missing from the vehicle, then the vehicle is not correctly certified and may be in noncompliance with the safety standards.