Interpretation ID: nht75-2.14

DATE: 08/19/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive the delay in responding to your letter of April 10, 1975, requesting an interpretation of S4.3, the placarding requirement, of Federal Motor Vehicle Safety Standard No. 110, Tire Selection and Rims -- Passenger Cars.

You have proposed a format for presenting vehicle capacity weights which is designed to accommodate, with a single placard, several different model configurations. The NHTSA has no objection to this format, provided that the weights listed are correct.

Sincerely,

ATTACH.

VOLKSWAGEN OF AMERICA INC.

April 10, 1975

Mark Schwimmer, Esq. -- Office of the Chief Counsel, National Highway Traffic Safety Administration

Subject: N40-30 (MPP)

Dear Mr. Schwimmer:

This is in reference to our telephone conversation of Monday, April 7, concerning the format of our Standard 110 label. I am also referring to Mr. Dyson's letter of January 17, 1975, in which he suggested that we list on the same label alternate vehicle capacity weights applicable to models with or without optional equipment as long as we initially displayed the lowest vehicle capacity weight for the vehicle.

Our marketing representatives feel that the initial listing of the lowest weight may have competitive disadvantages in the small car market and have proposed a format which contains the vehicle capacity weight for each model configuration. I have enclosed for your review a copy of the new format which we plan to use and would appreciate your opinion concerning its acceptability pursuant to S4.3 of FMVSS 110.

Sincerely,

Gerhard P. Riechel -- Attorney

Enc.

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