Mr. Gene Noll
Buyer
Fitz Auto Parts, Inc.
24000 Highway 9
Woodinville, WA 98072-9753

Dear Mr. Noll:

This is in reply to your letter of January 26, 1996, to Taylor Vinson of this Office. Your company's business is "the buying and selling of used auto parts". You would like to buy and import Canadian vehicles to be "dismantled for parts and then destroyed." You state that none of these vehicles "will be resold or have a chance of being put back on the road as a whole vehicle." You have asked for our opinion on how you might do this under the importation regulations that this agency administers.

Our laws do not address the question of the importation of a nonconforming motor vehicle for salvage purposes. There is no specific provision, therefore, that will permit you to do so. However, under our interpretations, a vehicle without an engine and transmission may be considered an assemblage of motor vehicle parts, rather than a motor vehicle. The assemblage can be imported as motor vehicle equipment. But it would be better to forego importation of the engines and transmissions in order to avoid creating the impression with Customs, E.P.A., and NHTSA that the engines and transmissions will be reinstalled, and that motor vehicles are, in fact, being imported without the intent of conforming them.

However, even under this scenario, certain equipment installed on a vehicle cannot be legally imported unless the equipment meets applicable Federal motor vehicle safety standards. This equipment includes brake hoses, lamps and reflectors, tires, rims for vehicles other than passenger, brake fluid, glazing, and seat belt assemblies. Generally, conformance of these items is indicated by the presence of a "DOT" symbol on them (lighting equipment may have "SAE" instead). Any of the items listed above that do not bear these symbols must be removed from a motorless vehicle before the assemblage may be imported.

If you have any further questions, you may refer them to Taylor Vinson (202-366-5263).

Sincerely,

Samuel J. Dubbin Chief Counsel ref:591 d:2/27/96