Mr. David Regan
    Trecan Combustion Limited
    4049 St. Margarets Bay Road
    Hubley, NS, B3Z IC2
    Canada


    Dear Mr. Reagan:

    This is in response to your fax of February 21, 2003, concerning the National Highway Traffic Safety Administration's (NHTSA) regulations governing vehicle certification found in 49 CFR 567. In your fax, you stated that your company manufactures trailers and intends to import them into the United States. You have enclosed a photocopy of a sample certification label that you intend to attach to your trailers. During a subsequent phone conversation, you indicated that the sample label is for a single axle trailer. You asked us to determine whether your sample certification label would be acceptable for use in the United States.

    By way of background, 49 CFR Part 567 specifies content, location and other requirements for the certification label or tag to be affixed to motor vehicles as required by section 49 U.S.C. 30115, 32504, and 33108. By affixing the label, the manufacturer certifies that the vehicle complies with all applicable Federal motor vehicle safety, bumper, and theft prevention standards.

    567.4(g) specifies the contents of the certification label or tag, which must include the following, in the order shown (emphasis added):

    (1) Name of manufacturer.
    (2) Month and year of manufacture.
    (3) "Gross Vehicle Weight Rating" or "GVWR."
    (4) "Gross Axle Weight Rating" or "GAWR," followed by the appropriate value in pounds for each axle, identified in order from front to rear (e.g., front, first intermediate, second intermediate, rear).
    (5) The statement: "This vehicle conforms to all applicable Federal motor vehicle safety standards in effect on the date of manufacture shown above." The expression "U.S." or "U.S.A." may be inserted before the word "Federal".
    (6) Vehicle identification number.
    (7) The type classification of the vehicle as defined in 46 CFR 571.3 of this chapter (e.g., truck, MPV, bus, trailer).

    The enclosed sample label contains all the information required by 567.4(g). However, some of the information in your label is out of order. As previously stated, 567.4(g) specifies that the information on the certification label must appear as it is listed in the standard. Therefore, the items within your sample certification label must be rearranged in order to comply with 567.4(g). An example of the appropriate arrangement of the information found on your sample label appears below:

    MANUFACTURED BY:

    TRECAN COMBUSTION LIMITED

    DATE DECEMBER 2002
    GVWR 6,500 KG (14,335 LB)
    GAWRALL5,806 KG (12,800 LB)
    TIRES 275/70R22.5 H
    RIMS 22.5X8.25
    COLD TIRE INFL 827 kPa (120 PSI) SINGLE
    THIS VEHICLE CONFORMS TO ALL APPLICABLE US FEDERAL MOTOR VEHICLE SAFETY STANDARDS IN EFFECT ON THE DATE OF MANUFACTURE SHOWN ABOVE.
    VIN XXXXXXXXXXXXXXXXX
    TYPE: TRAILER

    Please be advised that your certification label need not look exactly like the example above. However, the information within your label must appear in the exact same order. Because we are unsure whether the enclosed sample label is a scaled copy or a life-size representation, we note that 567.4(g) requires that the label be lettered in block capitals and numerals not less than three thirty-seconds of an inch high.

    For additional information for trailer manufacturers please visit our web site at: http://www.nhtsa.dot.gov/cars/rules/maninfo/trailer002.pdf. If you have any further questions regarding NHTSA's certification requirements for trailers, please feel free to contact George Feygin of my staff at (202) 366-2992.

    Sincerely,

    Jacqueline Glassman
    Chief Counsel

    ref:567
    d.4/11/03