Interpretation ID: aiam1508
Director of Sales
JacKnife Division
Breeze Corporations
Inc.
700 Liberty Avenue
Union
NJ 07083;
Dear Mr. Green: This is in reply to your letter of May 8, 1974, asking whether person installing on a new vehicle a device called the Breeze Jacknife Control are required to certify the conformity of the vehicle to applicable motor vehicle safety standards. You indicate such a device would ordinarily be installed after the truck leaves the factory.; Persons who install components on or otherwise modify complete vehicles before their sale to a purchaser for a purpose other than resale may be vehicle alterers under NHTSA Certification regulations (49 CFR Parts 567, 568), and if so are required to certify that the vehicle as altered conforms to applicable standards by attaching to it a label containing specified information. A label must be attached when the alteration either involves components which are not readily attachable or whose installation renders invalid the vehicle's stated weight ratings. Modifications to a completed vehicle after its purchase for purposes other than resale, however, do not give rise to any certification or labeling requirements.; Copies of the Certification regulations and information on obtainin copies of all NHTSA requirements are enclosed.; Yours truly, Richard B. Dyson, Assistant Chief Counsel