DICK KLEIN, consulting engineer for the National Association of Trailer Manufacturers (NATM), says that even though 49 CFR 571.110 requires trailers with a GVWR of 10,000 lb and under to have an additional label adjacent to the VIN certification label, he has seen many trailers that don't.
According to Section 4.3.5, Requirements for trailers, “Each trailer, except for an incomplete vehicle, must show the information … on a placard permanently affixed proximate to the certification label specified in 49 CFR part 567. Additionally, each trailer must on its placard contain a cargo capacity statement expressed as ‘The weight of cargo should never exceed XXX kilograms or XXX pounds’ in the same location on the placard specified for the ‘vehicle capacity weight’ statement required by this standard.”
“The reason was that prior to this time, a buyer could only see the GVWR of the trailer,” he said in an NATM convention presentation on certification and VIN labeling. “That's all he knew. Unless he weighed it, he had no idea what empty was, which he then could subtract from the GVWR to get the cargo capacity. So the Feds said, ‘We want you to do that subtraction for them, so you must publish that number.’ It's a big burden for you because if you manufacture a lot of different trailers with options, you have to weigh that trailer, subtract that from its GVWR and that different number becomes the cargo-carrying capacity.”
The placard lists the vehicle manufacturer's cold inflation for front, rear, and spare tires, along with the tire size designation, indicated by the headings “size” or “original tire size” and “spare” or “spare tire” for the tires installed at the time of first purchase for purposes other than resale.
The placard must say TIRE AND LOADING INFORMATION, and must be in the proper format and color scheme: red border, with a yellow block saying, SEE OWNER'S MANUAL FOR ADDITIONAL INFORMATION.
Requirements for the owners manual are laid out in 49 CFR 575, as follows:
“When a motor vehicle that has a GVWR of 10,000 pounds or less, except a motorcycle or low speed vehicle, and that is manufactured on or after September 1, 2005, is delivered to the first purchaser for purposes other than resale, the manufacturer shall provide to the purchaser, in writing in the English language and not less than 10 point type, a discussion of the items specified in paragraphs (a)(4)(i) through (v) of this section in the owner's manual, or, if there is no owner's manual, in a document:
“(i) Tire labeling, including a description and explanation of each marking on the tires provided with the vehicle, and information about the location of the Tire Identification Number (TIN);
“(ii) Recommended tire inflation pressure, including a description and explanation of: (A) Recommended cold tire inflation pressure; (B) The vehicle placard and tire inflation pressure label specified in Federal Motor Vehicle Safety Standard No. 110 and their location in the vehicle; (C) Adverse safety consequences of underinflation (including tire failure), and (D) Measuring and adjusting air pressure to achieve proper inflation.”
Klein said this requirement can be satisfied by getting copies of the National Highway Traffic Safety Administration (NHTSA) document, “Tires: Everything is Riding on It,” or by contacting NATM for a Word document that has the required language.
The rest of 49 CFR 575's content requirements:
“(iii) Glossary of tire terminology, including ‘cold tire pressure,’ ‘maximum inflation pressure,’ and ‘recommended inflation pressure,’ and all non-technical terms defined in S3 of FMVSS Nos. 110 & 139;
(iv) Tire care, including maintenance and safety practices;
(v) Vehicle load limits, including a description and explanation of: (A) Locating and understanding load limit information, total load capacity, seating capacity, towing capacity, and cargo capacity; (B) Calculating total and cargo load capacities with varying seating configurations including quantitative examples showing/illustrating how the vehicle's cargo and luggage capacity decreases as the combined number and size of occupants increases; (C) Determining compatibility of tire and vehicle load capabilities; (D) Adverse safety consequences of overloading on handling and stopping and on tires.
“(5) When a motor vehicle that has a GVWR of 10,000 pounds or less, except a motorcycle or low speed vehicle, and that is manufactured on or after September 1, 2005, is delivered to the first purchaser for purposes other than resale, the manufacturer shall provide to the purchaser, in writing in the English language and not less than 10 point type, the following verbatim statement, as applicable, in the owner's manual, or, if there is no owner's manual, in a document:
“ii) For trailers: “Steps for Determining Correct Load Limit: (1) Locate the statement “The weight of cargo should never exceed XXX kg or XXX lbs.” on your vehicle's placard. (2) This figure equals the available amount of cargo and luggage load capacity. (3) Determine the combined weight of luggage and cargo being loaded on the vehicle. That weight may not safely exceed the available cargo and luggage load capacity.”
Said Klein, “This is an unbelievably comprehensive requirement.”
49 CFR 566
The other part of the presentation was made by Featherlite's Norm Helmke, who went over the manufacturer identification requirements as laid out in 49 CFR 566.1 through 566.6:
It requires manufacturers of motor vehicles, and of motor vehicle equipment to which a motor vehicle safety standard applies, to submit identifying information and a description of the items they produce.
The purpose of this part is to facilitate the regulation of manufacturers under the National Traffic and Motor Vehicle Safety Act, and to aid in establishing a code numbering system for all regulated manufacturers.
“They do this for recall purposes,” Helmke said.
CFR 5676.5 says that each manufacturer must furnish the information to NHTSA: (a) full individual, partnership, or corporate name of the manufacturer; (b) residence address of the manufacturer and State of incorporation if applicable; and (c) description of each type of motor vehicle or of covered equipment manufactured by the manufacturer, including, for motor vehicles, the approximate ranges of gross vehicle weight ratings for each type.
It goes on to say: “(1) Except as noted below, the description may be of general types, such as ‘passenger cars’ or ‘brake fluid.’ (2) In the case of multipurpose passenger vehicles, trucks, and trailers, the description shall be specific enough also to indicate the types of use for which the vehicles are intended, such as ‘tank trailer,’ ‘motor home,’ or ‘cargo van.’ (3) In the case of motor vehicles produced in two or more stages, if the manufacturer is an incomplete vehicle manufacturer, the description shall so state and include a description indicating the stage of completion of the vehicle and, where known, the types of use for which the vehicle is intended. Example: ‘Incomplete vehicle manufacturer — Chassis-cab intended for completion as van-type truck.’ If the manufacturer is an intermediate manufacturer, or a final stage manufacturer, the description shall so state and include a brief description of the work performed. Example: ‘Multipurpose passenger vehicles: Motor homes with GVWR from 8,000 to 12,000 pounds. Final-stage manufacturer — add body to bare chassis.’ “
“It's up to each individual manufacturer how it wants to describe this to NHTSA,” Helmke said.
Helmke also went over the certification requirements listed in 49 CFR, 567.4:
“(a) Each manufacturer of motor vehicles (except vehicles manufactured in two or more stages) shall affix to each vehicle a label, of the type and in the manner described below, containing the statements specified in paragraph (g) of this section. (b) The label shall, unless riveted, be permanently affixed in such a manner that it cannot be removed without destroying or defacing it. (d) The label for trailers shall be affixed to a location on the forward half of the left side, such that it is easily readable from outside the vehicle without moving any part of the vehicle. (f) The lettering on the label shall be of a color that contrasts with the background of the label. (g) The label shall contain the following statements, in the English language, lettered in block capitals and numerals not less than three thirty-seconds of an inch high, in the order shown:
“Name of manufacturer: Except as provided in paragraphs (g)(1) (i), (ii), and (iii) of this section, the full corporate or individual name of the actual assembler of the vehicle shall be spelled out, except that such abbreviations as ‘Co.’ or ‘Inc.’ and their foreign equivalents, and the first and middle initials of individuals, may be used. The name of the manufacturer shall be preceded by the words ‘Manufactured By’ or ‘Mfd By.’ (2) Month and year of manufacture: This shall be the time during which work was completed at the place of main assembly of the vehicle. It may be spelled out, as ‘June 1970’, or expressed in numerals, as ‘6/70.’ (3) ‘Gross Vehicle Weight Rating’ or ‘GVWR,’ followed by the appropriate value in pounds, which shall not be less than the sum of the unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity. However, for school buses the minimum occupant weight allowance shall be 120 pounds. (4) ‘Gross Axle Weight Rating’ or ‘GAWR,’ followed by the appropriate value in pounds for each axle, identified in order from front to rear (e.g., front, first intermediate, second intermediate, rear). The ratings for any consecutive axles having identical gross axle weight ratings when equipped with tires having the same tire size designation may, at the option of the manufacturer, be stated as a single value, with label indicating to which axles the ratings apply.
“Examples of Combined Ratings: GAWR: (a) All axles — 4080 with 7.00-15 LT (D) tires. (b) Front — 12,000 with 10.00-20(G) tires. First intermediate to rear — 15,000 with 12.00-20(H) tires.
“(5) The statement: ‘This vehicle conforms to all applicable Federal motor vehicle safety standards in effect on the date of manufacture shown above.’ The expression ‘U.S.’ or ‘U.S.A.’ may be inserted before the word ‘Federal’.
(6) Vehicle identification number. (7) The type classification of the vehicle as defined in §571.3 of this chapter (eg ‘Trailer’).”
Helmke said that as stated in 565.4, each vehicle manufactured in one stage shall have a VIN that is assigned by the manufacturer. Each vehicle manufactured in more than one stage shall have a VIN assigned by the incomplete vehicle manufacturer. Vehicle alterers, as specified in 49 CFR 567.7, shall utilize the VIN assigned by the original manufacturer of the vehicle.
He said each VIN shall consist of 17 characters. A check digit shall be part of each VIN. The check digit shall appear in position nine of the VIN, on the vehicle and on any transfer documents containing the VIN prepared by the manufacturer to be given to the first owner for purposes other than resale. The VINs of any two vehicles manufactured within a 30-year period shall not be identical.
The VIN of each vehicle shall appear clearly and indelibly upon either a part of the vehicle, other than the glazing, that is not designed to be removed except for repair or upon a separate plate or label that is permanently affixed to such a part.