ID: nht87-1.88

TYPE: INTERPRETATION-NHTSA

DATE: 06/04/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Cameron-Nott

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Peter Cameron-Nott 90 Horace St: Stratford, CT 06497

This replies to your March 31, 1987 letter asking for a clarification of my January 16 letter to you regarding the importation of rebodied automobiles.

Specifically, you asked which Form HS-7 declaration is proper upon entry of a vehicle incorporating a 1966 chassis, upon which is mounted a new body whose individual equipment items meet current Federal motor vehicle safety standards applicable to them ( i.e. glazing, tires, brake hoses, lighting equipment, seat belts). The Customs officials you have contacted are unsure whether entry should be made under Box 1 or Box 3 of Form HS-7.

As we advised you earlier, a rebodied vehicle retaining its original chassis components, title, and identification number is considered to retain its original model year designation, even with a new body installed on it. Therefore, your vehicle would be considered a 1966 model. Accordingly, Box 1 would be the proper declaration: that the vehicle was manufactured on a date when no applicable safety standards were in effect. Box 3 is clearly inappropriate as there is no legal requirement for such a vehicl e to be brought into conformity with Federal safety standards. Should conformance of the individual equipment items be questioned - unlikely in our opinion -Box 2 would appear to be the appropriate declaration for these items: that they conform to all ap plicable standards and bear the manufacturer's certification to that effect (the DOT symbol on these items).

I hope that this answers your question.

Sincerely,

Erika Z. Jones Chief Counsel

Ms. Erika Z. Jones Chief Counsel NHTSA 400 Seventh Street. S.W. Washington, D.C. 20590

Dear Ms. Jones:

Thank you for your letter dated January 16th concerning my questions regarding rebodied cars(copy Enclosed). I do however have a point which requires clarification.

The car is a rebodied 1966 vehicle as per paragraph #1 however the windshield, tires, brake hoses, head lights and seat belts have been replaced and have the appropriate D.O.T. FMVSS markings on them as well as paid receipts for these items.

I have asked U.S. Customs in N.Y. how I should make the customs entry on form HS-7. They have suggested that I write to you for clarification because a pre 1968 car normally is entered under section #1 however because of these equipment changes they cann ot tell me whether I should file under section #1 or section #3.

In order to avoid delays and confusion upon arrival at customs I should be grateful if you would advise me under which section D.O.T. requires the entry to be made.

Your early reply would be greatly appreciated.

Sincerely,

Peter Cameron-Nott

See 1/16/87 letter from Erika Z. Jones to Peter Cameron-Nott

ID: 86-6.2

TYPE: INTERPRETATION-NHTSA

DATE: 12/01/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Alvin A. Leach

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Alvin A. Leach Manager Corporate Transportation Services Carolina Power & Light Co. PO BOX 1551 Raleigh, NC 27602

Dear Mr. Leach:

Thank you for your letter of September 5, 1986, to Administrator Steed concerning the safety belt installation requirements for heavy trucks. The Administrator has asked my office to respond since you asked for an interpretation of the requirements of Standard No. 208, Occupant Crash Protection. I hope the following discussion answers your questions.

You first asked whether lap/shoulder safety belts are required in a truck with a gross vehicle weight rating greater than 10,000 pounds. 54.3 of the standard, a copy of which is enclosed, sets out the requirements for such trucks. S4.3 permits a manufacturer to install either a lap safety belt, referred to as a Type 1 belt in the standard, or a lap/shoulder belt, referred to as a Type 2 belt, in a heavy truck. At the present time, we do not have any plans to require lap/shoulder belts in heavy trucks. We are taking steps to improve the comfort and convenience of safety belt systems in heavy vehicles. As explained in the attached notice, the agency is currently considering several changes to the standard which would make it easier to use safety belts in heavy vehicles. We expect to issue a final rule on this subject later this year.

If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

Ms. Diane K. Steed Administrator National Highway Traffic Safety Administration 400 Seventh Street, S. W. Washington, DC 20590

Reference: Seat Belt Requirements for Trucks with G.V.W.R. of More Than 10,000 Pounds per Motor Vehicle Safety Standard No. 208

Dear Ms. Stead:

I have been asked to respond to a question from one of our employees about seat belt requirements for trucks in the 20,000 pounds G.V.W. range. His question was "Why aren't our medium duty (20,000 lb. G.V.W.) trucks purchased with lap and shoulder belts like those required in cars?"

Apparently they are not required by Standard No. 208 and are not offered by the manufacturers.

I would appreciate it if you could tell me if our interpretation of Standard No. 208 is correct. I would also like to know if there are any plans to require lap and shoulder belts in this size vehicle.

Your assistance is appreciated.

Yours very truly,

Alvin A. Leach, Manager Corporate Transportation Services

ID: 8626

St. F. Steiner
Consultant
AET Network
2190 3rd Street
San Francisco, CA 94107

Dear Sir or Madam:

We have received your "Dear Mr. Van Orden" letter of May 4, 1993, which was addressed to me. You wish to import 3- and 4- wheeled vehicles from Europe "for research and exploration", and have asked several questions relating to U.S. laws and D.O.T. requirements.

Your first question is: "Are there any safety standards and regulations for the above mentioned automobiles?"

The answer is yes. All 3-wheeled motor vehicles are considered "motorcycles" for purposes of compliance with the Federal motor vehicle safety standards that apply to motorcycles. Depending upon their configuration, but not upon their weight, 4-wheeled vehicles are either "passenger cars", "multipurpose passenger vehicles", "trucks", or "buses" for purposes of the safety standards.

However, motor vehicles intended solely for purposes of research may be imported without the necessity of conforming them to the safety standards under the terms and conditions that the agency has set out in 49 CFR Part 591.

Your second and third questions are whether there is a minimum speed standard regulation or weight limitations for the vehicles you wish to import. The answer is no. However, a motorcycle with 5-horsepower or less is considered a "motor- driven cycle", and some of the motorcycle standards impose lesser requirements for motor-driven cycles, and motor-driven cycles whose speed attainable in l mile is 30 mph or less.

Your fourth question relates to the conversions required to meet U.S. specifications and standards. As indicated previously, no conversion is required when the importation is solely for the purpose of research. If you wish to import vehicles that have been originally manufactured to meet the Federal motor vehicle safety, bumper, and theft prevention standards, the manufacturer will find those standards at 49 CFR Parts 571, 581, and 541, respectively. If you wish to import nonconforming vehicles for conversion after importation, then the agency must determine that the vehicles are eligible for entry pursuant to 49 CFR Part 593, and importation and conversion accomplished through a Registered Importer pursuant to 49 CFR Part 592.

Your final question is whether the vehicles will be permitted on highways. This is a question that is not answerable under Federal law. Each State determines the criteria for licensing motor vehicles for use on the roads under its jurisdiction. If a State does not license a vehicle for on-road use (all terrain vehicles, minibikes, golf carts are examples), a basis exists for a manufacturer to determine that its vehicles are not "motor vehicles." If a vehicle is not a motor vehicle, i.e. one manufactured primarily for on-road use, then no Federal safety standards apply to it.

If you have any further questions about the importation process, you should refer them to Mr. Van Orden at our Office of Vehicle Safety Compliance, Office of Enforcement.

Sincerely,

John Womack Acting Chief Counsel

ref:591 d:5/17/93

ID: nht76-1.46

DATE: 03/08/76

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Georgette A. Sears

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of January 6, 1976, requesting information as to the Federal standards and regulations that are applicable to the manufacture of an "18' pull type horse/stock trailer combination."

Manufacturers of trailers of the type you describe must certify that their product is in compliance with Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, 49 CFR 571.108, and Standard No. 120, Tire Selections and Rims for Vehicles Other Than Passenger Cars, 49 CFR 571.120. Please note, however, that Standard No. 120 is not effective until August 1, 1976, for the rim marking requirements (S5.2), and September 1, 1976, for the remaining requirements, so trailers manufactured before these times will not have to be certified as being in compliance with Standard No. 120.

The procedure for certification is specified in 49 CFR Part 567, and requires the manufacturer to affix a label to his product certifying that it is in compliance with the requirements of applicable Federal regulations. You should check the trailer that you purchase to make certain there is a certification label. Part 567.4(d) specifies that the certification label for trailers shall be affixed to a location on the forward half of the left side, such that it is easily readable from outside the vehicle without moving any part of the vehicle.

There are no Federal regulations concerning the connection of trailers to trucks or other vehicles. Nevertheless, from a safety stand point it is important that you ascertain the hauling capacity of your truck-trailer system in order to avoid overloading that could create potential safety hazards. You should obtain information from the manufacturer concerning the "tongue weight" of the trailer when fully loaded, and relate it to the gross axle weight ratings of your towing vehicle, found on its certification label on the door or door post. The trailer manufacturer may also have further recommendations as to the capacity of the vehicle needed to tow one of his trailers safely.

Please contact us if we can of any further assistance.

YOURS TRULY,

EASTERN TURTLE TOP

TO: U.S. Gov't-Dept of Transportation National Transportation Safety Board General Info.

SUBJECT: Trailer Safety Date: Jan. 6, 1976

Gentlemen: I would like to know what Federal Standards apply to the building of an 18' pure type horse/stock trailer combination. I am in the process of ordering one from a company in Ohio (ARK) and want to be certain it is a safe carrier - including the connection to my pick-up truck. Can you help me to ascertain what is considered safest for our personal safety and the safety of others on the road? Thank you. (P.S. This transfer will haul 4-Horses or 6 (11001b) show cattle ----)

Sincerly, Georgette A. Sears

ID: nht88-2.81

TYPE: INTERPRETATION-NHTSA

DATE: 08/01/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: ROBERT G. YORKS -- VICE PRESIDENT AND GENERAL MANAGER, AUTOMOTIVE BUSINESS GROUP, TRUCK-LITTLE CO.

TITLE: NONE

ATTACHMT: MEMO DATED 5-24-88, TO KATHLEEN DEMETER, FROM ROBERT G. YORKS, 25220; MEMO UNDATED, TO ROBERT G. YORKS, FROM KATHLEEN DEMETER

TEXT: We have received your letter of May 24, 1988, withdrawing your request for confidential treatment of your letter of March 31 concerning the legality of a new safety lighting device. This letter also responds to your inquiry of July 14.

The device is described as a "combination center high-mounted stop lamp and cargo lamp". The functions are optically separate. The cargo lamp can illuminate the cargo box on pick-up trucks, while on vans and utility vehicles it serves as a "utility lig ht". The device is intended to be used as either original or aftermarket equipment.

The Federal motor vehicle safety standard on vehicle lighting is Standard No. 108. As you know, the center high-mounted stop lamp is required only for passenger cars. Further, there is no requirement that a center lamp intended for other types of motor vehicles meet the passenger car lamp requirements (for example, those requirements would prohibit combining the center lamp with the cargo lamp). As neither function of your device is required on lighting equipment for vehicles other than passenger car s, Standard No. 108 permits the installation of your device as original equipment provided that it does not impair the effectiveness of the lighting equipment that the standard does require. Whether impairment exists is initially a determination of the manufacturer of the vehicle who certifies compliance with Standard No. 108. However, the issue of impairment is ultimately subject to a determination by this agency. Types of impairment that can exist include functional interference with the wiring of o ther lamps, creation of ambiguous or confusing signals to such a degree that it may obscure the message of lamps and reflectors required by Standard No. 108, and reduction of photometrics below the minimum levels specified.

As an item of aftermarket lighting equipment, it is subject to a restriction of the National Traffic and Motor Vehicle Safety Act that its installation by a manufacturer, dealer, distributor, or motor vehicle repair business must not render inoperative i n whole or in part any device or element of design installed in accordance with a Federal motor

vehicle safety standard. We construe this prohibition strictly and equate it with impairment. If performance is "impaired," it can be viewed as "inoperative" with respect to achieving the purpose for which it has been installed.

Assuming that installation of an aftermarket device is not restricted by the Act, it nevertheless remains subject to the laws of a State in which the vehicle is registered and driven. We are not conversant with State laws on combination rear lamps, but you may wish to consult the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203, for an opinion.

I hope that this answers your questions.

ID: 2523y

The Honorable Lawrence J. Smith
U. S. House of Representatives
Washington, D.C. 20515

Dear Mr. Smith:

I am writing in response to your letter forwarding correspondence from your constituent, Mr. Joel Leitson, with respect to litigation recently brought by the United States against several firms that install plastic film, or "tint," on automobile windows.

You have asked about the statutory authority under which these suits were brought. Pursuant to section 103 of the National Traffic and Motor Vehicle Safety Act of 1966 ("Safety Act"), 15 U.S.C. 1392, the National Highway Traffic Safety Administration ("NHTSA") has issued safety standards applicable to new motor vehicles and items of motor vehicle equipment. One of the standards that we have issued under this authority is Federal Motor Vehicle Safety Standard No. 205, Glazing Materials (49 CFR 571.205), which applies to all new vehicles and all new glazing materials for use in motor vehicles. Among the requirements set forth in Standard No. 205 are specifications for minimum levels of light transmittance (70 percent light transmittance in areas requisite for driving visibility, which includes all windows in passenger cars).

Section 108(a)(i)(A) of the Safety Act, 15 U.S.C. 1397(a)(1)(A), provides that no person may manufacture or sell any vehicle unless it is in conformity with all applicable safety standards. Pursuant to section 108(b)(1) of the Safety Act, 15 U.S.C. 1397(b)(1), this paragraph does not apply after a vehicle is first sold to a consumer. However, both before and after the first sale, section 108(a)(2) of the Safety Act, 15 U.S.C. 1397(a)(2), provides that "No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . . ."

Thus, by installing tint film on automobiles that reduces the light transmittance of their glass below 70 percent, the firms in question have been rendering those vehicles "inoperative," in violation of the Safety Act. The same principle would apply to a service station that removed an airbag or a safety belt from a vehicle, since such an action would create a noncompliance with the occupant protection requirements of NHTSA's standards.

You also asked for our comments on whether Florida's statutes are preempted by these suits. We assume that you are referring to the provision of Florida law that prohibits the operation of any vehicle in the State of Florida that has glazing with less than 35 percent light transmittance. This statute, and similar statutes adopted by other states, do not purport to legitimize conduct -- the rendering inoperative of glazing by tint installation firms -- that is illegal under the Safety Act. Thus, there is no conflict with Federal law, and Florida may continue to enforce its operating rules.

I hope that this responds to your questions. If we can be of further assistance, please let me know.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:205#VSA d:6/25/90

ID: nht81-3.12

DATE: 09/02/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: The Firefly Company, Inc.

TITLE: FMVSR INTERPRETATION

TEXT:

SEPTEMBER 2, 1981 NOA-30

Mr. Alex Roth The Firefly Company, Inc. 1 Marine Plaza North Bergen, New Jersey 07047

Dear Mr. Roth:

This is in reply to your letter of July 30, 1981, asking for confirmation that a vehicle you intend to produce is a "motorcycle."

The body appears to be that of the British Reliant Regal, a three-wheeled fully enclosed passenger vehicle. You intend to market your product as a battery powered three-wheeled vehicle. Although this agency once engaged in rulemaking with the intent of excluding three-wheeled vehicles of this nature from applicability of the motorcycle standards, no final rule was ever adopted. Therefore, all three-wheeled vehicles are classified as "motorcyles" for purposes of compliance with the Federal motor vehicle safety standards.

I hope that this is responsive to your request.

Sincerely,

Frank Berndt Chief Counsel

July 30, 1981

Mr. Frank Berndt Chief Counsel NHSTA 400 Seventh St., S.W. Washington, D.C. 20590

Dear Mr. Berndt:

We are at the threshold of mass producing what we believe will be America's first low-cost, battery-powered vehicle.

The vehicle is specifically designed for city streets use and made for the 30 million multi-car families in the U.S. many of whom could do with one standard gasoline-powered car and our battery-powered vehicle to carry one or two passengers to work; to the railroad station; or to do the myriad transportation chores that lie close to the household.

If we are successful with our mass production plans, we expect to be able to retail this vehicle at under $4,000. If we do this, it will indicate the viability of the electric vehicle market and get the electric vehicle industry off dead center.

This is a two-passenger, three-wheeled vehicle with a fiberglass body. Overall length is 131 inches - height 56 inches - width 54 inches. The curb weight is estimated to be 1,200 lbs.

We have had conversations with motor vehicle commissioners in various states, all of whom indicate to us that this vehicle would be licensable as a motorcycle. Early conversations with John Carson, your safety standards engineer, also indicated to us that there were no DOT or NHSTA standards for three-wheeled vehicles of this type and that, consequently, it would be classified as a motorcycle.

We are addressing ourselves to your office to request confirmation of these facts.

I am enclosing a photograph of the preproduction prototype and would be happy to furnish you with any additional information that you might require.

Sincerely yours,

THE FIREFLY COMPANY, INC.

Alex Roth

AR:lvrn Enclosure

ID: nht74-1.20

DATE: 07/23/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Toyo Rubber Industry Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your July 8, 1974, question whether publication of a brochure that lists the rims that may be used with the tires produced by Toyo Tire Corporation would meet the requirements of S5.1 of Standard No. 119, New pneumatic tires for vehicles other than passenger cars.

Publication of such a brochure would meet the requirement of S5.1 so long as the tires are listed in accordance with S5.1(a), that is by manufacturer name or brand name, followed by a listing of rims that may be used with each tire listed. The brochure would have to be supplied to dealers of the manufacturer's tires, to any person upon request, and in duplicate to: Tire Division, National Highway Traffic Safety Administration, 400 Seventh Street, S.W., Washington, D.C. 20590.

Yours truly,

ATTACH.

National Highway Traffic Safety Administration -- Docket Section

SUBJECT: Federal Motor Vehicle Safety Standard No. 119, S5 Tire and Rim Matching Information

Dear Sir:

FMVSS No. 119 is requiring as follows:

S5 Tire and Rim Matching Information

S5.1 Each manufacturer of tires shall ensure that a listing of the rims that may be used with each tire that he produces is provided to the public in one of the following forms:

(a) Listed by manufacturer name or brand name in a document furnished to dealers of the manufacturer's tires, to any person upon request, and in duplicate to: Tire Division, National Highway Traffic Safety Administration, 400 Seventh Street, S.W., Washington, D.C. 20590; or

(b) Contained in publications, current at the date of manufacture of the tire or any later date, of at least one of the following organizations:

The Tire and Rim Association.

The European Tyre and Rim Technical Organization.

Japanese Industrial Standards.

Deutsche Industrie Norm.

The Society of Motor Manufacturers & Traders, Ltd.

British Standards Institution.

Scandinavian Tire and Rim Organization.

In case any particular tire and rim matching information is not contained in the publications mentioned in S5.1(b), and since S5.1(a) requires the tire manufacturer to provide a document to the public, we are going to use as a document a brochure which shows the tire and rim combination to be used.

We understand that such a brochure would comply with the requirement of S5.1. Please let us know your opinion as to whether our understanding is correct or not.

Should our understanding be incorrect, please let us know what kind of document we must provide to the public.

Your prompt reply would be greatly appreciated.

Sincerely, Y. Takami -- Technical Representative, TOYO RUBBER INDUSTRY COMPANY, LTD.

ID: nht79-1.41

DATE: 08/09/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Porshe

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of May 25, 1979, requesting clarification of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays. You asked whether the rear window defogger switch, which emits a dim light for control location and a brighter light upon activation, is considered a control or a telltale.

Although the switch might be regarded as a control, telltale, or both, it is regulated as a control insofar as its illumination is concerned. Therefore, its illumination must be continuously variable as specified in S5.3.3 of the standard.

S5.3.3 provides that

Each passenger car . . . manufactured with any control listed in S5.1 or in column 1 of Table 1, and each passenger car . . . with any display listed in S5.1 or in column 1 of Table 2, shall meet the requirements of this standard for the location, identification, and illumination of such control or display.

The rear window defrosting and defogging system appears in the control list of S5.1 and in Table 1, but not in the display list of S5.1 or in Table 2. Therefore, the control illumination requirements of S5 apply to the defogging switch and the display illumination requirements do not.

If you have any further questions, please do not hesitate to write.

SINCERELY,

UNITED STATES COMPLIANCE OFFICE

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION Office of the Chief Counsel

May 25, 1979

Subject: PART 571, FMVSS 101-80, Docket 1-18, Notice 13 Control Location, Identification and Illumination

Dear Sirs:

In Table 1 of the above docket, the rear window defrosting and defogging system control shall be illuminated.

S 5.3.3 reads: "Light intensities for controls etc. and their identification shall be continously variable. . ."

In the same paragraph it reads: "The light intensity of each telltale shall not be variable and shall be such that, when activated, that telltale and its identification are visible to the driver under all daytime and nighttime conditions."

In one of our cars, the Porsche 928, the dashboard illumination and a dim light inside the rear window defogger switch are activated when the ignition is turned on. The dim light within the defogger switch is meant to help to locate this control. Upon activation of this switch the light intensity of the defogger switch is increased to show that the rear window defogger switch is in the "on" position. Both light intensities, dim to locate the control, and brighter for activation, are not variable.

Please clarify if w should consider the light in the rear window defogger switch a "telltale" or a "Control" and if we are in compliance with the 2 different light intensities.

We enclose 2 pictures from the owner's manual to show the location and activation of the switch.

Thank you in advance for your clarification.

Gerhard C. Waizmann

Enclosures omitted.

ID: nht93-3.45

DATE: May 17, 1993

FROM: John Womack -- Acting Chief Counsel, U.S. Department of Transportation, NHTSA (Signature by Stephen P. Wood)

TO: St. F. Steiner -- Consultant, AET Network

TITLE: None

ATTACHMT: Attached to letter dated 5-4-93 from St. F. Steiner to John Womack (OCC 8626)

TEXT: We have received your "Dear Mr. Van Orden" letter of May 4, 1993, which was addressed to me. You wish to import 3- and 4- wheeled vehicles from Europe "for research and exploration", and have asked several questions relating to U.S. laws and D.O.T. requirements.

Your first question is: "Are there any safety standards and regulations for the above mentioned automobiles?"

The answer is yes. All 3-wheeled motor vehicles are considered "motorcycles" for purposes of compliance with the Federal motor vehicle safety standards that apply to motorcycles. Depending upon their configuration, but not upon their weight, 4-wheeled vehicles are either "passenger cars", "multipurpose passenger vehicles", "trucks", or "buses" for purposes of the safety standards.

However, motor vehicles intended solely for purposes of research may be imported without the necessity of conforming them to the safety standards under the terms and conditions that the agency has set out in 49 CFR Part 591.

Your second and third questions are whether there is a minimum speed standard regulation or weight limitations for the vehicles you wish to import. The answer is no. However, a motorcycle with 5-horsepower or less is considered a "motordriven cycle", and some of the motorcycle standards impose lesser requirements for motor-driven cycles, and motor-driven cycles whose speed attainable in 1 mile is 30 mph or less.

Your fourth question relates to the conversions required to meet U.S. specifications and standards. As indicated previously, no conversion is required when the importation is solely for the purpose of research. If you wish to import vehicles that have been originally manufactured to meet the Federal motor vehicle safety, bumper, and theft prevention standards, the manufacturer will find those standards at 49 CFR Parts 571, 581, and 541, respectively. If you wish to import nonconforming vehicles for conversion after importation, then the agency must determine that the vehicles are eligible for entry pursuant to 49 CFR Part 593, and importation and conversion accomplished through a Registered Importer pursuant to 49 CFR Part 592.

Your final question is whether the vehicles will be permitted on highways. This is a question that is not answerable under Federal law. Each State determines the criteria for licensing motor vehicles for use on the roads under its jurisdiction. If a State does not license a vehicle for on-road use (all terrain vehicles, minibikes, golf carts are examples), a basis exists for a manufacturer to determine that its vehicles are not "motor vehicles." If a vehicle is not a motor vehicle, i.e. one manufactured primarily for on-road use, then no Federal safety standards apply to it.

If you have any further questions about the importation process, you should refer them to Mr. Van Orden at our Office of Vehicle Safety Compliance, Office of Enforcement.