Interpretation ID: 11477MLS

Mr. Martin J. Beckenbach
President
PVC Molding Technologies, Inc
181 West Shore Blvd.
Newark, NY 14513

Dear Mr. Beckenbach:

This responds to your inquiry about whether there are any existing or planned standards or requirements that apply to automotive floormats. In particular, you asked whether any local, state, or Federal standard addresses an automotive floormat=s Askid resistancy@; its backing texture or grain; its thickness, weight or profile; its flammability resistance; or any other characteristic.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards (FMVSSs) that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, Congress has established a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. The agency periodically tests new vehicles and items of equipment for compliance with the standards.

As for existing Federal standards, Federal Motor Vehicle Safety Standard No. 302, Flammability of Interior Materials, (copy enclosed) applies to materials, such as floor mats, used in the occupant compartment of new motor vehicles. Standard No. 302 specifies burn resistance requirements for materials used in the occupant compartment of new motor vehicles. Section S4.1 lists the components in vehicle occupant compartments that the vehicle manufacturer must certify as complying with the flammability resistance requirements of paragraph S4.3. One of the components listed is floor coverings. Because Standard No. 302 is a vehicle standard, the manufacturer of the vehicle, and not the manufacturer of the individual component, is responsible for certifying compliance with Standard No. 302. The standard does not apply to individual components sold separately from a vehicle, such as floormats sold in the aftermarket.

There are no other Federal standards that apply to the other characteristics of floor mats about which you asked. Even though there are no other such Federal standards, you should be

aware that under 49 U.S.C. ''30118-30121, the manufacturer of the floormat is responsible for ensuring that the floormat is free of safety-related defects. (This responsibility is borne by the vehicle manufacturer where the mats are installed on a new vehicle by or with the express authorization of that vehicle manufacturer.) If the floormat (or vehicle) manufacturer or NHTSA determines that a safety related defect exists, the manufacturer would be responsible for notifying purchasers of the defective vehicle or equipment and remedying the problem free of charge.

With regard to state or local requirements, you should contact state or local authorities for information about any applicable standards. The Automotive Manufacturers Equipment Compliance Agency, Inc. may have helpful information on whether any such authority has requirements for floormats. That organization can be reached at 1090 Vermont Avenue, N.W., Suite 1200, Washington, D.C. 20005, telephone (202) 898-0145.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel ref: 302 d:3/25/96