Interpretation ID: Tesa.jeg

Mr. Dave Adams

Market ManagerAutomotive, N.A.

Tesa Tape, Inc.

5825 Carnegie Blvd.

Charlotte, NC 28209

Dear Mr. Adams:

This responds to your letter asking about certain logo parts marking requirements of Part 541. You stated that your company offers a feature called Advanced Embossed where you utilize a technology to embed a customers logo into your acrylic label material so that the label shows the manufacturer and the label cannot be counterfeited. You provided a sample of the label and requested confirmation that the product meets Part 541 and that additional laser engraving of such a logo or identifier is not needed. The issues raised by your letter are addressed below.

NHTSA does not provide approvals or endorsements of motor vehicles or motor vehicle equipment. Our opinion is based on the facts provided in your letter and outlined above and on the analysis presented below.

Part 541, Federal Motor Vehicle Theft Prevention Standard, requires certain passenger motor vehicles to have identifying numbers affixed or inscribed on specified parts. See

541.5(a). The standard specifies a number of label requirements for affixing the identifying number to a part. See 541.5(d) and (d)(1). Among other things

541.5(d)(1)(viii) specifies that:

(t)he logo or some other unique identifier of the vehicle manufacturer must be placed in the material of the label in a manner such that alteration or removal of the logo visibly alters the appearance of the label.

We have examined the sample you submitted. We note that the logo of a vehicle manufacturer is embedded in the acrylic label material such that the background of the material has a glossy surface, and the logo stands out by having a non-glossy surface. It is our view that this approach can be used to comply with 541.5(d)(1)(viii) and that additional laser engraving of such a logo would not be required by that paragraph.

As indicated above, Part 541 specifies a number of label requirements for affixing the identifying number to a part. A manufacturer using labels must ensure that they comply with all specified requirements.

I hope this information is helpful. If you have any further questions, please feel free to call Edward Glancy of my office at (202) 366-2992.

Sincerely yours,

Anthony M. Cooke

Chief Counsel

ref:541

d.11/20/08