Interpretation ID: 14937.ztv
Chairman, Committee on Appropriations
United States Senate
Washington, DC 20510-6025
Dear Mr. Chairman:
Thank you for your recent letter to the Department on behalf of your constituent, Brad Brown of Anchorage. Mr. Brown ordered a Chevy Suburban and discovered that it was made in Mexico. He believes that the law on motor vehicle content labeling should be amended to require dealers to disclose the country of origin when a vehicle is ordered. I appreciate the opportunity to address this issue.
By way of background information, the National Highway Traffic Safety Administration's regulations on motor vehicle content labeling were issued pursuant to the American Automobile Labeling Act. This Act has been codified at 49 U.S.C. section 32304. The law requires that new Chevy Suburbans and other passenger motor vehicles have affixed an informational label that includes, among other things, the city and country of the final assembly plant of the vehicle (49 CFR 583(a)(3)). Thus, in the case of a vehicle which is ordered, the purchaser would not see the label until delivery of the vehicle.
While we appreciate Mr. Brown's concern, we do not believe it would be practicable to change the law to require dealers to disclose the country of origin when a vehicle is ordered, since many vehicle models today are assembled in more than one location. The Chevy Suburban, for instance, is also produced in Janesville, Wisconsin. It is our understanding that dealers do not place orders with specific assembly plants. Unless a vehicle model is assembled in a single location, the dealer would not know from which assembly plant the ordered vehicle will be delivered.
It is probable that the most a dealer could do is to inform a prospective purchaser of the location of the assembly plants for the model desired, and that the vehicle will come from one of these. However, a prospective purchaser could likely obtain this information now from a dealer simply by asking. I note that although the prospective purchaser might be able to examine the
domestic content label on similar new vehicles on the dealer's lot to determine their country of origin, this would not necessarily mean that his or her vehicle would be assembled in the same location.
I hope this information is helpful. If you or your staff have any further questions, please feel free to contact me at (202) 366-5265.
Sincerely,
John Womack
Acting Chief Counsel
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