Interpretation ID: nht81-1.7

DATE: 01/22/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Convenient Machines Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of December 22, 1980, asking "acceptance" of the CUB three-wheeled vehicle "for import certification."

We confirm the advice given you by Mr. Vinson of this office in your recent telephone conversation with him. The CUB is classified as a "motorcycle" for purposes of compliance with the Federal motor vehicle safety standards. If CUBs are manufactured to comply with all standards applicable to motorcycles (see Title 49 Code of Federal Regulations, Part 571), and have a label permanently attached certifying that fact (49 CFR 567), this is all that is needed to fulfill the requirements of this agency for importation and sale in the United States, under the joint regulations issued by the Departments of Transportation and Treasury (19 CFR 12.80).

If, in advance of regular production, you wish to import several noncomplying vehicles for purposes of test or experimentation, this is allowable, provided that at the time of entry a statement is attached to the declaration form that will be given the importer, stating the purpose for which the vehicle is being imported, the estimated time it will be on the public roads, and the disposition that will be made at the end of the period allowed (one year, renewable upon request). (19 CFR 12.80(b)(1)(vii)).

SINCERELY,

December 22, 1980

National Highway Traffic Safety Administration Office of Chief Council

Following my recent telephone conversation with you, and at the suggestion of Mr. John Carson, we are enclosing photographs and preliminary specifications of our C.B. "CUB" 3 wheeled 2 passenger I.E.C. powered vehicle.

These vehicles will be manufactured in Taiwan for Convenient Machines Inc. We intend to distribute and sell them in the United States following the gradual start of production in March 1981.

We understand that at the present time this vehicle is classified as a 3 wheeled motorcycle. We intend to full comply with the standards and regulations for this classification of vehicle as outlined in the TITLE 49 CODE of REGULATIONS as necessary for a certificate of acceptance for U.S. Customs entry purposes.

The attached photographs show the #1 prototype "CUB" on which certain further improvements are now in work. A more final version is shown in the 1/10th scale 4 view layout which indicates a larger hatchback door and better lite and vent locations. We expect to have 3 samples of these approximately February 15 and several will then be brought here at that time.

We feel that this vehicle not only complies with the regulations but also offers a number of additional safety features which are highly desirable. These are fully described in the enclosed list of features and specifications.

After your review of this material will you kindly send us a letter relative to the acceptance of this vehicle for import certification. If you find there are any requirements omitted please advise us so we can take immediate steps to include them. We will greatly appreciate your reply at the earliest possible date as we are now tooling up for production to commence pending your approval.

If you have any further questions on any aspect of the "CUB" design and specifications please call me at 212 249 2424. I will be out of town from Dec 28 thru January 15 in which case you can contact Mr. Phil Prince at 212 594 6895.

We look forward to your approval of our compliance program on this vehicle and thank you for your cooperation.

Richard H. Arbib Vice President-Design