ID: nht68-1.48

DATE: 01/12/68

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: Road and Track

TITLE: FMVSR INTERPRETATION

TEXT: In response to your letter of December 19 to Mr. Boaz regarding the proposed regulations governing the importation of motor vehicles and how they affect racing cars, I enclose a copy of the final regulations which are now in effect. You will see that 19 C.F.R. 12.80(b)(7) permits importation of noncomplying motor vehicles for purposes of competition if they are not licensed for use on the public roads.

ID: nht80-3.7

DATE: 06/23/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. William Tierney

TITLE: FMVSS INTERPRETATION

TEXT: This is to follow-up on your phone conversation of June 10, 1980, with Stephen Oesch of this office concerning the Federal requirements applicable to the installation of auxiliary fuel tanks in passenger cars.

I am enclosing a copy of a letter of interpretation the agency issued last August which discussed the general implication of such installations under Federal law. If after reviewing this material you have any additional questions, please contact Mr. Oesch.

ID: nht90-1.14

TYPE: INTERPRETATION-NHTSA

DATE: JANUARY 9, 1990

FROM: MEHDI ROWGHANI -- DALLAS EUROPEAN PARTS DISTRIBUTORS

TO: TAYLOR VINSON -- OFFICE OF CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 4-9-90 TO MEHDI ROWGHANI FROM STEPHEN P. WOOD; (A35; STD. 214; PART 541) TEXT:

We are importers/distributors of parts for European cars. We are repeatedly asked by our customers if importation and sale of European doors (without reinforcement bars) is in accordance with the rules and regulations of the Department of Transportation . May we request you to clarify this point for us.

ID: nht68-2.35

DATE: 06/04/68

FROM: AUTHOR UNAVAILABLE; william H. Risteen; NHTSA

TO: Clauson Manufacturing Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of May 20, 1968, to Mr. Bridwell, concerning pickup covers, has been referred to me for reply.

Pickup covers which you describe are considered to be in the same category an slide-in campers and are items of motor vehicle equipment for use in motor vehicles. As such pickup covers must meet the requirements of Federal Motor Vehicle Safety Standard No. 205, Glazing Materials-Passenger Cars, Multipurpose Passenger Vehicles, Trucks, Buses and Motorcycles.

ID: nht72-3.12

DATE: 06/09/72

FROM: ELWOOD DRIVER FOR ROBERT L. CARTER -- NHTSA

TO: S.P.A. Carrozzeria Pininfarina

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 25, 1972, inquiring about the applicability of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, and FMVSS No. 302, to the rear windows of convertible cars.

In FMVSS No. 302, the convertible top is not intended to refer to the rear window, but has reference only to the overhead material. Flammability of the transparent glazing material is regulated by FMVSS No. 205.

ID: aiam0137

Dear Mr. Green: Thank you for your letter of January 23, 1969, to William Haddon, Jr. M.D., requesting information on Federal standards for child restraint devices.; I am enclosing a copy of Federal Motor Vehicle Safety Standard No. 209 Seat Belt Assemblies - Passenger Cars, Multipurpose Passenger Vehicles, Trucks and Buses' which includes requirements for a Type 3 seat belt assembly for persons weighing not more than 50 pounds and capable of sitting upright by themselves.; The technical requirements of the present standard No. 209 wer previously included in Standards for Seat Belts for Use in Motor Vehicles (15 CFR Part 9, 31 F.R. 11528)' which was incorporated by reference in the initial Standard No. 209. I am also enclosing copies of these previous documents.; We are in the process of developing a standard for child car seats an I am enclosing a copy of a recently issued Notice of Proposed Rule Making on this subject. It is important to note that this is only a *proposed* regulation and the requirements may be modified somewhat when the final rule is published. However, this proposed rule indicates those safety features which are considered to be important for a child car seat.; There are no other existing Federal standards on child restrain systems for use in motor vehicles.; Sincerely, Clue D. Ferguson, Director, Office of Standards o Crash-Injury Reduction, Motor Vehicle Safety Performance Service;

ID: aiam2624

Dear Mr. McNeil: This responds to your May 25, 1977, letter asking whether two sampl certification labels you submitted comply with the requirements of Part 567, *Certification*, and Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; The National Highway Traffic Safety Administration (NHTSA) does no issue advance approvals of compliance with Federal safety standards or regulations. The agency will, however, give you an informal opinion as to whether your labels appear to comply with the requirements. The two labels you submitted do not follow the format required by Part 567 for certification labels. Therefore, they do not appear to comply with the requirements. Your method of stating tire and rim sizes differs from that required in Part 567 and Standard No. 120. For example, you state your tire and rim information as follows: '10-20-F-Tires-7.5 Rims at 75 PSI Cold Dual.' By the requirements of Part 567 and Standard No. 120 as they apply to certification labels, this information should read: '10.00-20(F) tires, 20x7.5 rims, at 75 psi cold dual.' Further, the statement after GAWR 'maximum with minimum size tire-rims shown below' should be deleted from the certification label. I am enclosing a copy of Part 567 and Standard No. 120 for your information.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam4636

Dear Mr. Aston: This is in reply to your letter with respect to you wish to import motor vehicle parts from England, to be used in the construction of a kit car for your own use. I regret the delay in responding. You have informed us that you are not importing parts controlled by the Federal motor vehicle safety standards, such as 'lights, tires, brake hoses, glazing materials,' or 'the engine, transmission, wheels, instruments, and miscellaneous items that are readily available here'. Instead, you will be importing 'body parts, frame parts, suspension and some steering parts, some electrical parts and the gas tank.' From your description, we believe that your intention is to import motor vehicle equipment and not a motor vehicle. The only items of motor vehicle equipment which are covered by the Federal motor vehicle safety standards, and hence must comply or be brought into compliance with those standards are: brake hoses, brake fluid, lighting and reflective devices, passenger car tires, retreaded tires, tires and rims for vehicles other than passenger cars, wheel covers, warning devices, glazing, seat belt assemblies, and child seating systems. If the motor vehicle equipment you are importing includes none of these items, then the equipment may be entered without the necessity of giving a bond for the production of a statement that it has been brought into compliance. I hope that this letter is helpful to you. Sincerely, Stephen P. Wood Acting Chief Counsel;

ID: aiam2619

Dear Mr. Gromer: This responds to your May 6, 1977 letter asking whether your tir information label complies with the requirements of Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*, and Part 567, *Certification*. Further, you request that the National Highway Traffic Safety Administration (NHTSA) expedite treatment of Docket No. 73-31, Notice 1, which, if implemented would simplify the certification and information labels.; Concerning Docket 73-31, the NHTSA published on June 20, 1977, a notic (42 FR 31161) implementing Notice 1 which proposed the use of the designation 'all axles' rather than listing each axle individually on the certification label. The implementation of this regulation should resolve many of your problems.; Regarding the sample information label you submitted with your letter the NHTSA does not give advance approvals of compliance with Federal safety regulations or standards. We will, however, giver an informal opinion of whether your label appears to comply with the requirements. The label you submitted does not appear to comply with the requirements of Part 567 or Standard No. 120. I have enclosed copies of both these regulations for your information.; Your certification label should use the designation 'all axles' no 'each axle.' The tire and rim information should follow that designation stated in the form presented in the examples in Standard No. 120 and Part 567.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam2622

Dear Mr McNeil: This responds to your May 25, 1977, letter asking whether two sampl certification labels you submitted comply with the requirements of Part 567, *Certification*, and Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; The National HIghway Traffic Safety Administration (NHTSA) does no issue advance approvals of compliance with Federal safety standards or regulations. The agency will, however, give you an informal opinion as to whether your labels appear to comply with the requirements. The two labels you submitted do not follow the format required by Part 567 for certification labels. Therefore, they do not appear to comply with the requirements. Your method of stating tire and rim sizes differs from that required in Part 567 and Standard No. 120. For example, you state your tire and rim information as follows: '10-20-f-Tires-7.5 Rims at 75 PSI Cold Dual.' By the requirements of Part 567 and Standard No. 120 as they apply to certification labels, this information should read: '10.00-20(f) tires, 20x7.5 rims, at 75 psi cold dual.' Further, the statement after GAWR 'maximum with minimum size tire-rims shown below' should be deleted from the certification label. I am enclosing a copy of Part 567 and Standard No. 120 for your information.; Sincerely, Joseph J. Levin, Jr., Chief Counsel