Interpretation ID: aiam3074
Director
Automotive Safety Office
Ford Motor Company
The American Road
Dearborn
MI 48121;
Dear Mr. Eckhold: This is in response to your letter of August 3, 1979, asking whethe Ford may ship to distributors and dealers vehicles with bumper guards, needed for compliance with Part 581, *Bumper Standard* (49 CFR Part 581), placed inside the vehicles for installation prior to sale of the vehicles to consumers. You state that the bumper guards, which would be attached by dealers and others making use of pre-processed mounting holes in the vehicle bumpers, would reduce railroad car capacity, if installed prior to shipment. You also suggest that absence of reference in the Customs regulations (19 CFR Part 12) to readily attachable components needed to comply with regulations issued under the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 1901), may lead to complications in the importation of vehicles prior to installation of readily attachable bumper components.; The National Highway Traffic Safety Administration has no objection t the shipment of vehicles with readily attachable bumper components stored in the vehicles for later installation, provided the components are attached before the vehicles are offered for sale to the first purchaser for purposes other than resale. Further, regulations governing importation of motor vehicles (19 CFR 12.80) apply only to compliance with Federal motor vehicle safety standards, as set forth in 49 CFR Part 571, and the question of compliance with Part 581, therefore, should not arise.; Sincerely, Frank Berndt, Chief Counsel