Interpretation ID: nht94-4.70

TYPE: INTERPRETATION-NHTSA

DATE: October 28, 1994

FROM: Richard J. Kinsey -- Manager, Fuel Economy Planning & Compliance, Ford Motor Company

TO: Ricardo Martinez -- MD, Administrator, NHTSA

TITLE: None

ATTACHMT: ATTACHED TO 3/8/95 LETTER FROM PHILIP R. RECHT TO RICHARD J. KINSEY (REDBOOK (2)); PART 583

TEXT: Ford Motor Company requests your concurrence on the following procedure for defining the domestic content and country of origin for foreign-sourced allied and outside supplier components.

40 CFR 583.6(c)(4)(iv) assigns zero domestic content to all passenger motor vehicle equipment which is imported into the territorial boundaries of the United States or Canada from a third country, even if part of its material originated in the United States or Canada. 40 CFR 583.7 allows the supplier to use methodologies that are used for customs purposes to determine the country of origin. Ford expects that for any imported component, both allied and outside, suppliers would report that the domest ic content is zero and the country of origin is the country of manufacture, based on the rules of substantial transformation.

Ford can obtain the same information (zero domestic content, country of manufacture, purchase price) expected to be received from our foreign suppliers from our present purchasing systems. Since the process of soliciting the supplier is costly, Ford plans to assign the domestic content and country of origin of the foreign supplied components without soliciting the data from our foreign suppliers. We are concerned that even if Ford did submit the request to foreign suppliers, that suppliers would ha ve to expend additional resources creating a document which Ford already knows the answer. Even if the foreign supplier does not respond, the domestic content and country of origin will not be any different than if they did respond. Ford believes that requiring these suppliers to respond would impose costly and unnecessary burdens on our foreign suppliers.

Ford will solicit content information from all first-tier outside suppliers of non-minor parts starting for the 1996 model year calculation.

Please contact Ron Peltier at (313) 337-5367 if you have any questions.