Interpretation ID: nht90-1.100

DATE: MARCH 29, 1990

FROM: JERRY W. MOONEY -- RESIDENT AGENT IN CHARGE, DEPT. OF THE TREASURY, U.S. CUSTOMS SERVICE TO: STEVEN WOOD -- ACTING CHIEF COUNSEL, NHTSA

TITLE: FILE SV08PLOSV001

ATTACHMT: ATTACHED TO LETTER DATED 4-25-90 TO JERRY W. MOONEY FROM

STEPHEN P.WOOD; (A35; IMPORT REG.) TEXT:

Our office requests your assistance in an Investigation involving seventeen (17) M151A2 military jeeps illegally imported into the United States from Napierville, Quebec, Canada. S/A Todd Petrie of this office was advised by DOT Compliance Officer, Fred Coutts, to provide you with a written request.

The M151A2 is a quarter ton military jeep first produced for the Department of Defense by A. M. General Division in 1972. The investiga- tion has shown that these vehicles were imported into the country without declaring them as vehicles. The Customs declarations simply stated "miscellaneous jeep parts." No HS-7 declarations were filed. The vehicles were whole, intact jeeps. In addition, the jeeps were concealed inside containers and covered with parts.

To assist in this investigation, please respond to the following:

We are of the understanding that a list does not exist naming certain vehicles as being noncomplying. If not, what is the procedure to determine if a vehicle complies to DOT standards?

We are of the understanding that the M151A2 does not comply to DOT standards. What makes it a noncomplying vehicle?

Does the fact that the M151A2 was manufactured for DOD make it a noncomplying vehicle?

If you have any questions, contact S/A Todd Petrie or me at (912) 944-4341. Your assistance in this matter is greatly appreciated.