It is necessary to consider this since a manufacturer could be highly integrated in operation but, for variety reasons, use multiple corporations. Second, assuming the answer is yes, we look beyond the corporate structure and consider whether the companies are operationally independent from each other.
First, we consider whether the companies are structured such that they can be considered separate persons under the statutory definition. In considering whether related companies are separately eligible for parts marking exemptions, we believe it is appropriate to consider two issues. (B) importing motor vehicles or motor vehicle equipment for resale. (A) manufacturing or assembling passenger motor vehicles or passenger motor vehicle equipment or The definition of manufacturer for the theft prevention standard program is set forth at 49 U.S.C. We have previously addressed the issue of how related companies are treated for purposes of parts marking exemptions in an interpretation to Patrick M. As discussed below, based on available information, we believe that Hyundai and Kia are eligible as separate manufacturers for parts marking exemptions. You asked us to reconsider this position.
(HATCI) for the 2009 Hyundai Genesis, NHTSA staff informally advised HATCI that it appeared to be ineligible for a second exemption for the same model year. Because our agency had already granted a petition submitted by Hyundai-Kia American Technical Center, Inc. Under 49 CFR Part 543.5(a), a manufacturer may, for each model year, petition the National Highway Traffic Safety Administration (NHTSA) for an exemption of one vehicle line from the requirements of the Vehicle Theft Prevention Standard. This responds to your Novemletter, as well as an earlier letter from Hyundai-Kia America Technical Center, Inc., concerning a petition you submitted requesting an exemption from the parts marking requirements of Part 541, Federal Motor Vehicle Theft Prevention Standard, for the Kia Amanti beginning with the 2009 model year.
Hyundai-Kia America Technical Center, Inc.
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