Interpretation ID: nht90-1.46

TYPE: INTERPRETATION-NHTSA

DATE: 02/15/90

FROM: SATOSHI NISHIBORI -- VICE PRESIDENT INDUSTRY/GOVERNMENT AFFAIRS NISSAN RESEARCH AND DEVELOPMENT

TO: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 05/31/90 FROM STEPHEN P. WOOD -- NHTSA TO SATOSHI NISHIBORI -- NISSAN RESEARCH; REDBOOK A35; VSA 102[5]; PART 575.6

TEXT: This letter is to request your interpretation regarding the recent amendment to NHTSA's Consumer Information regulations set forth in 49 CFR Part 575. This amendment, published on November 27, 1989, requires that vehicle Owner's Manuals contain specifie d information regarding NHTSA's toll-free Auto Safety Hotline.

Section 575.6(a)(2)(i) of the regulations specifies a statement that must appear in Owner's Manuals effective September 1, 1990. In two locations within the statement, the "name of manufacturer" must be inserted. We request your opinion as to whethe r we may, consistent with the regulations, use the name "Infiniti" in these spaces, for manuals used with our new Infiniti line of vehicles.

Infiniti is a Division within Nissan Motor Corporation in U.S.A., the importer of Nissan and Infiniti vehicles. The Infiniti vehicles will be assembled by Nissan Motor Company, Ltd., the parent corporation, in Japan. Vehicles sold through the Infinit i Division will be designated by the Infiniti nameplate, and we expect that consumers will identify the vehicles specifically with that name. The process is similar to that used with the Cadillac or Lincoln Divisions of General Motors Corporation or For d Motor Company, respectively.

We would provide an address and telephone number for the Infiniti Division adjacent to the required Hotline information, to facilitate consumers contacting Infiniti. This toll free number would be unique to the Infiniti Division, and calls would be a nswered by a staff separate from that of the Nissan Division. We believe that this approach would not confuse consumers and would, in fact, improve their ability to contact quickly the appropriate officials who are authorized to respond to any questions on defect or compliance matters concerning Infiniti models.

We would greatly appreciate your earliest possible response on this matter, so that we can arrange our printing schedules to meet the September 1 effective date. Thank you for your consideration of this matter.