Interpretation ID: aiam3775
Mazda (North America)
Inc.
23777 Greenfield Road
Southfield
MI 48075;
Dear Mr. Nakaya: This responds to your October 13, 1983 letter regarding th classification of certain hypothetical mini- van models as either passenger cars, multipurpose passenger vehicles, or trucks for purposes of complying with Federal motor vehicle safety standards.; Your first question involved the effect of changes in floor pa geometry on this classification. You postulate separate cargo and passenger versions of the mini-van, with each version using identical suspension, steering and driveline components and each vehicle being of unibody construction. However, slight differences would exist in the floor pans of the two vehicles, with the passenger version having a lowered floor pan section to accommodate the rear seat.; Assuming that the cargo version has greater cargo-carrying volume tha passenger carrying volume (see, e.g., 49 CFR Part 523), we would consider that version to be a truck. (In the unlikely event the cargo version does not have that ratio of volumes, all versions of the mini-van would probably be considered passenger cars.) Since the passenger version of a mini-van would almost certainly have greater passenger-carrying volume than cargo carrying volume, that vehicle would be treated as a passenger car unless it meets the agency's 'multipurpose passenger vehicle' definition. That definition provides, in relevant part, that an MPV is a motor vehicle designed to carry 10 people or less and which is constructed on a 'truck chassis.' The 'chassis' of a vehicle includes the vehicle's power train as well as its entire load supporting structure. In the case of a vehicle using unibody construction, this load supporting structure would technically include the floor pan.; The fact that a common chassis is used in a family of vehicles, on member of which is classified as a 'truck,' is evidence that the common chassis is a 'truck chassis.' However, further evidence is needed to demonstrate that the chassis has truck attributes, such as information showing the design to be more suitable for heavy duty, commercial operation than a passenger car chassis. This further evidence is necessary since otherwise the introduction of a cargo carrying version of an existing passenger car could result in the reclassification of the passenger car into an MPV, if the agency only considered the issue of whether a common chassis is used. For example, in the past, certain station wagons have been marketed without rear seats and with other modifications which render them the functional equivalent of a cargo van. The agency does not believe it to be appropriate in such a situation to reclassify the basic station wagon as an MPV.; The floor pan differences mentioned in your first question do no appear to be so significant as to require treating the two mini-van versions as having different chassis. The agency does not consider minor floor pan differences to negate the fact that two versions of the same family of vehicles employ the same 'chassis,' since to do so would likely mean that no unibody vehicles could be classified as MPV's. However, in the absence of any information regarding the extent to which the common chassis has truck-like attributes, we cannot state whether the vehicle would be treated as an MPV.; Your second question involves the effect of various seating designs o whether a unibody constructed mini-van is classified as an MPV. Since the seats are not part of the vehicle chassis, these variations should have no impact on whether the vehicle is an MPV. (Fuel economy classifications are dependent on seat configuration however--see 49 CFR Part 523.); Your third question involves the significance of the relative sale levels, order of introduction, and actual existence of two versions (cargo and passenger) of the mini-van. In theory, a passenger version of a mini-van could be classified as an MPV even if no cargo version were offered in the U.S. or indeed if none were ever produced. In such a situation, however, the manufacturer would be under a heavy burden to demonstrate that what is sold as a passenger carrying vehicle in fact has a 'truck chassis,' with heavy duty, commercially suited attributes. The existence of a truck version, and the fact that the truck version was either designed first or was the principal focus of the design would be additional factors which would tend to indicate that the chassis is a truck chassis.; If you have further questions in this matter, please contact us. Sincerely, Frank Berndt, Chief Counsel