13061 Lakeridge Dr.
Spanish Lake, MO 63138-3307
Dear Mr DeVan:
This is in reply to your e-mail of January 2, 1997, to this Office. You informed us that you are building a "one-of-a-kind" truck/van, and need information such as how you can get a copy of the National Highway Traffic Safety Administration's "codes," whether you need a manufacturer's license, and how you "go about getting certification for GVWR, Safety, and Emissions?"
Under our primary safety statute, 49 U.S.C. Chapter 301, Motor Vehicle Safety, "manufacturer" means any person manufacturing or assembling motor vehicles . Even if someone produces only a single motor vehicle, that vehicle must be certified to conform to all applicable Federal motor vehicle safety standards if its producer intends it to operate on the public roads. The Federal motor vehicle safety standards are found at Title 49 Code of Federal Regulations Part 571. As we are unsure of the final configuration of your "truck/van," you should review the definitions of "truck" and "multipurpose passenger vehicle" under Sec. 571.3(b) to see which is most appropriate to your vehicle. The application section near the beginning of each Federal safety standard will tell you whether that standard applies to multipurpose passenger vehicles and trucks.
I enclose an information sheet that will tell you how you may get a copy of Title 49. No Federal license is required to manufacture a vehicle or vehicles, though a manufacturer of vehicles must file a simple identification statement with the agency.
Manufacturers must certify compliance of their vehicles with the Federal safety standards on the basis of their own engineering judgment and test data. Certification is achieved through affixing a plaque permanently to the vehicle (49 C.F.R. Part 567), which contains the vehicle's GVWR.
The Environmental Protection Agency enforces Federal emissions regulations, and we are unable to advise you as to their applicability to your truck/van.
We appreciate your interest in the Federal motor vehicle programs. If you have any further questions, you may call Taylor Vinson of this Office at 202-366-5263. Because of the public interest in our interpretations and our desire to make them available to all interested persons, it is not our policy to reply by e-mail to requests for interpretations.
Acting Chief Counsel