Interpretation ID: HARMER.ZTV
P.O. Box 721
Bountiful, Utah 84011
FAX 801-299-0523
Dear Mr. Harmer:
This is in reply to your letter of June 4, 1996, asking the following question:
"Whether or not certification of an automobile for sale in Puerto Rico as being in compliance with Federal safety standards would allow that automobile to be imported into the fifty states insofar as compliance with applicable Federal motor vehicle safety standards is concerned?"
The answer is yes, as you have represented to Daewoo.
49 U.S.C. 30112(a) prohibits the importation into the "United States" of a motor vehicle manufactured on or after the date an applicable Federal motor vehicle safety standard takes effect unless the vehicle complies with the standard and is covered by the manufacturer's certification of compliance with the standard. Although the term "United States" is not defined, we view it as comprising all States, and "State" is a defined term. Under 49 U.S.C. 30102(a)(10), a "State" means "a State of the United States, the District of Columbia, Puerto Rico, the Northern Mariana Islands, Guam, American Samoa, and the Virgin Islands." This means that a motor vehicle that Daewoo manufactures to conform, and that it certifies as conforming, with all applicable Federal motor vehicle safety standards, may be freely imported into Puerto Rico or into any other "State" as defined above as in compliance with DOT safety regulations.
I hope that this is responsive to your request. If you have further questions, you may refer them to Taylor Vinson of this Office (202-366-5263).
Sincerely,
Samuel J. Dubbin Chief Counsel ref:591 d:6/6/96