ID: 3237o

Mr. T. J. Brown
General Manager, Product Services
Mohawk Tire Company
l500 Indiana Avenue
P.O. Box 3250
Salem, Virginia 24l53

Dear Mr. Brown:

This responds to your letter requesting an opinion concerning Federal Motor Vehicle Safety Standard No. l09, New Pneumatic Tires. According to your letter, you are considering purchasing for resale a group of metric size tires from a foreign manufacturer. The maximum load and maximum pressures molded on the sidewalls of the tires are indicated in kilograms and kilopascals only, without any indication of the maximum pounds and PSI pressure. The actual stamping on the tires is as follows:

l65SRl5 Load Range B Maximum Load 530kgs - Maximum Pressure 230 KPA l85SRl4 Load Range B Maximum Load 600kgs - Maximum Pressure 230 KPA l75SRl4 Load Range B Maximum Load 560kgs - Maximum Pressure 230 KPA l65SRl3 Load Range B Maximum Load 475kgs - Maximum Pressure 230 KPA l55SRl3 Load Range B Maximum Load 420kgs - Maximum Pressure 220 KPA

You stated that you question whether the omission of the load designation and pressure in pounds prohibits the tires from being sold in the United States and requested our opinion on the matter. As discussed below, it is our opinion that tires without the maximum load and maximum pressures molded on the sidewalls in English units do not meet the requirements of Standard No. l09 and therefore cannot be imported into the United States for use on passenger cars.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its motor vehicles or equipment meet applicable requirements. The following represents our opinion based on the facts provided in your letter.

All tires imported into the United States for use on passenger cars must be certified as complying with Federal Motor Vehicle Safety Standard No. l09. The standard specifies performance requirements (strength, endurance, high speed, and resistance to bead unseating), marking requirements (treadwear indicators and labeling information), and tire and rim matching information requirements which must be satisfied by each tire sold in the United States.

Section S4.2.l(b) of Standard No. l09 requires that the maximum permissible inflation pressure of each tire "shall be either 32, 36, 40 or 60 psi, or 240, 280, 300 or 340 kPa." Thus, no value other than those listed may be used for the maximum permissible inflation pressure of a passenger car tire. Sections S4.3(b) and (c) of the standard specify that each tire shall have permanently molded onto the sidewalls the maximum permissible inflation pressure and the maximum load rating for the tire.

Section S4.2.l(b) originally listed only three permissible maximum inflation pressures, all in English units (32, 36 and 40 psi). The agency interpreted sections S4.3(b) and (c) to require that the maximum permissible inflation pressure and maximum load rating be in English units, since this is the system of measurement which will be used and understood by most consumers.

The first permissible metric maximum inflation pressures, 240 and 280 kPa, were added to Standard No. l09 in l977. 42 FR 12869, March 7, l977. In permitting metric-series tires, the agency established a requirement that the metric unit inflation pressure and load rating be supplemented by English system equivalents on the tire sidewall. That requirement, set forth in section S4.3.4, now reads as follows:

S4.3.4 If the maximum inflation pressure of a tire is 240, 280, 300 or 340 kPa, then:

(a) Each marking of that inflation pressure pursuant to S4.3(b) shall be followed in parenthesis by the equivalent inflation pressure in psi, rounded to the next whole number; and

(b) Each marking of the tire's maximum load rating pursuant to S4.3(b) shall be followed in parenthesis by the equivalent load rating in pounds, rounded to the nearest whole number.

Thus, each tire must have a maximum inflation pressure of either 32 psi, 36 psi, 40 psi, 60 psi, 240 kPa, 280 kPa, 300 or 340 kPa. If the maximum inflation pressure is 32 psi, 36 psi, 40 psi, or 60 psi, the maximum permissible inflation pressure and maximum load rating provided pursuant to sections S4.3(b) and (c) must be in English units. I would note that so long as the information appears in English units, there is no reason that it cannot also be expressed in equivalent metric units, if the presentation of the additional information does not cause confusion about the required information. If the maximum permissible inflation pressure is 240 kPa, 280 kPa, 300 or 340 kPa, the maximum permissible inflation pressure in kPa provided pursuant to section S4.3(b) must be followed in parenthesis by the equivalent inflation pressure in psi, rounded to the next higher whole number, and the maximum load rating provided pursuant to section S4.3(c) in kilograms must be followed in parenthesis by the equivalent load rating in pounds, rounded to the nearest whole number.

Since the tires you are considering purchasing do not have the maximum load and maximum pressures molded on the sidewalls in English units, they do not meet the requirements of Standard No. l09 and may not be imported into the United States for use on passenger cars. I have also enclosed for your information a copy of a December l2, l985, letter, addressed to Mutual Trading Corporation, which provides a general discussion of issues related to the importation and sale of tires in the United Sates.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosures

/ref:109 d:ll/23/88

ID: New Holland Tire

ID: Interpretation-ElectraMeccanica-May 22 2024

May 22, 2024

Mr. Isaac Moss
Chief Administration Officer
ElectraMeccanica
EMV Automotive USA, Inc.
11647 Ventura Blvd.
Studio City, CA 91604 

Dear Mr. Moss: 

This letter responds to your request, on behalf of the ElectraMeccanica Automotive USA, Inc., for guidance as to whether passenger car tires certified to meet Federal Motor Vehicle Safety Standard (FMVSS) No. 139 may be installed on new motorcycles. 

Your letter references a December 30, 1982 interpretation letter confirming that paragraph S5.1.1 of FMVSS No. 120 permitted a motorcycle to be equipped with passenger tires certified as complying with FMVSS No. 109, as long as the tires were fitted to rims listed as suitable for use with the equipped tires, and as long as those rims met the marking requirements of FMVSS No. 120.1 You note that since this 1982 interpretation letter, FMVSS No. 120 has been revised. Although you do not note this in your letter, since 1982, the National Highway Traffic Safety Administration (NHTSA) has substantially updated tire requirements and new passenger car tires are now required to meet FMVSS No. 139. You ask three questions in your letter, and I will address each in turn. 

First, you ask whether NHTSA can expand its December 30, 1982 interpretation letter to include passenger cars meeting the requirements of FMVSS No. 139. I can confirm for you that FMVSS No. 120 allows new motorcycles to be equipped with tires certified to meet FMVSS No. 139. This is explicitly stated in paragraph S5.1.1 of FMVSS No. 120. 

Second, you ask whether NHTSA can confirm that NHTSA would reference S4 of FMVSS No. 139, in lieu of the references to S4.4 of FMVSS No. 109 and S5.1 of FMVSS No. 119 

1 Letter to Anonymous (Confidential) (Dec. 30, 1982), available at https://www.nhtsa.gov/interpretations/1982-337  

Page 2
Mr. Isaac Moss 

contained in S5.1.1 of FMVSS No. 120. The answer to this question is yes. If tires certified to meet FMVSS No. 139 are installed on a new motorcycle, the tire manufacturer must list the rims as suitable for use with those tires in accordance with S4 of FMVSS No. 139. This requirement is consistent with the tire and rim matching information for tires certified with FMVSS Nos. 109 or 119. S4 of FMVSS No. 139, like S4.4 of FMVSS No. 109 and S5.1 of FMVSS No. 119, provides for disclosure of the rims that may be used with each tire a manufacturer produces. The tire’s manufacturer may make this disclosure either in a specific document provided to dealers of the manufacturers’ tires and to NHTSA, or in a yearbook published by one of several tire and rim standards organizations. 

Third, you ask whether NHTSA can provide guidance on whether compliance with FMVSS No. 110 is required in addition to FMVSS No. 120 when tires certified to meet FMVSS No. 139 are used on motorcycles. The answer to this question is no. FMVSS No. 110 is not applicable to motorcycles, even if tires meeting FMVSS No. 139 are installed on motorcycles. S2 of FMVSS No. 110 explicitly excludes motorcycles from the applicability of FMVSS No. 110. The only tire selection and rim standard applicable to motorcycles is in FMVSS No. 120. 

I hope this information is helpful. If you have any further questions, please feel free to contact David Jasinski of my office at (202) 366-2992. 

Sincerely,
Adam Raviv
Chief Counsel

Dated: 5/22/24
Ref: Standard No. 139

ID: aiam3776

Dear Mr. Duvall: We have received your letter of October 27, 1983, informing us of you plans to provide a front-end replacement kit for 1971-77 Chevrolet Vegas. You have asked whether incorporating a 1973 bumper mounting hardware will meet safety regulations. You have also asked for a copy of front lighting requirements, and for information on how you may certify your kit for national distribution.; As you have not provided us with a description of all equipment item in the kit, I can offer only general guidance. There are very few requirements for fabricators of kits intended to modify used vehicles. The Federal motor vehicle safety standards are of two types: those that apply to vehicle systems, and those that apply to individual equipment items. The so-called 'bumper standard' is an example of a systems standard. Standard No. 215, *Exterior Protection*, which applied to passenger cars manufactured between September 1, 1972, and September 1, 1978, did not directly apply to the bumper itself but established a level of damage resistance to be met by the vehicle in low-speed frontal impacts.; On the other hand, the vehicle lighting standard applies to bot lighting systems and replacement lighting equipment. The primary statutory obligation of a kit supplier lies in this area--to determine if any item of equipment in the kit is covered by an equipment standard, and then to insure that the item meets the standard. For example, Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*, required 1971-77 Chevrolet Vegas to be equipped with sealed beam headlamps. Were unsealed European headlamps to be furnished as part of the kit, that sale would be in violation of the National Traffic and Motor Vehicle Safety Act. Other equipment standards cover brake hoses, tires, brake fluids, glazing, and seat belts. Usually the manufacturer of equipment items covered by standards will certify compliance with Federal requirements by marking them with the symbol 'DOT'. In that event, no recertification by the kit supplier is required.; A further important obligation of a kit supplier is to insure tha safety-related defects are absent, or do not develop, in any motor vehicle equipment that he fabricates. If such occur, he is required to notify purchasers and remedy the defects.; There is also a provision of the Safety Act that has some relevance t your operation. Although a vehicle owner may modify his car in any manner he chooses, a restriction is established on modifications by others. That restriction is that 'no device or element of design' added to a vehicle enabling it to comply with a safety standard shall be 'rendered inoperative in whole or in part.' Thus, were a repair shop to remove the Vega front end and replace it with yours, the shop must insure that the Vega upon reassembly remains in compliance with the standards that originally applied to it. Although the kit supplier is not required under the Safety Act to insure that the Vega continues to comply with Standard No. 215, such insurance obviously assists the modifier in meeting its Federal responsibilities, and your incorporation of a 1973 bumper and attachments is helpful. The modified Vega must also continue to meet Federal lighting requirements, such as being equipped with front side marker lamps, and having no cover or other object over the headlamps when they are in use.; To assist you, I enclose copies of Standards Nos. 108 and 215 as the were in effect on October 1, 1977, the requirements were substantially the same for the other years in which you are interested. There is no charge and I am returning your check. If you have further questions, we shall be happy to answer them.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam4945

Your ref: ST-9015/91 Dear Mr. Suzuki: This responds to your letter o October 16, l991, to the Director, Office of Public and Consumer Affairs, with reference to the 'Safety Shot' lighting device that you have developed. You have enclosed photographs illustrating three types of this device in operation. In brief, the device consists of a center red highmounted stop lamp, immediately flanked by amber lamps that serve as supplementary turn signal/hazard warning signal lamps. Although the photos are not entirely clear, the device appears to consist of segmented compartments in a common housing, with thicker dividers separating the signal and stop functions. Type I incorporates an L.E.D. and is mounted at the top of the rear window. Type II also incorporates an L.E.D. and is mounted at the bottom of the window. Type III is located at the top of the rear window and uses conventional bulbs for its light source. You have been referred to us by Chrysler Corporation. We assume that you approached Chrysler with a view towards having your device accepted as original motor vehicle equipment. You have asked for our views on whether it is possible to use this device in the U.S. market. In the United States, the applicable Federal motor vehicle safety standard for rear lighting is Standard No. 108, Lamps, Reflective Devices, and Associated Equipment. Section S5.4 of Standard No. 108 does not allow a center high-mounted stop lamp to be physically combined with any other lamp or reflective device. Because Safety Shot appears to have a common housing for signalling and stopping functions, the lamps are 'combined' within the meaning of the prohibition. This means that the Safety Shot may not be used as original equipment on motor vehicles, and it may not be offered as a replacement for original equipment center highmounted stop lamps (required on each passenger car manufactured on or after September 1, l985). If you wish to sell the Safety Shot as an accessory in the aftermarket, for passenger cars manufactured before September 1, l985, different considerations apply. Installation of the Safety Shot by a manufacturer, distributor, dealer, or motor vehicle repair business is not permitted if it renders inoperative, in whole or in part, the function of any other rear lighting device. The question, therefore, is whether the effectiveness of the function of any other rear lighting device is compromised by the Safety Shot to the extent that the other device's function is rendered, at the minimum, partially inoperative. We note that original equipment amber signal lamps are not prohibited from flashing when the stop lamps are operating. It would not appear that the addition of the Safety Shot to a passenger car manufactured before September 1, l985, would compromise the signals from the original turn signal and stop lamps in a manner to render them, at least, partially inoperative. However, the Safety Shot is subject to regulation by the individual States of the United States in which it is sold or used. We are unable to advise you on State laws, and suggest that you write for an opinion to American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. Motor vehicles are also required to be manufactured to conform to Standard No. 111, Rearview Mirrors. Under this standard, if installation of the Safety Shot prevents the vehicle from meeting the rearview mirror field of view requirements specified, the manufacturer, distributor, dealer, or motor vehicle repair business installing the Safety Shot must install a rear view mirror on the passenger side of the vehicle (as a practical matter, most vehicles in the U.S. are manufactured with this additional mirror). Sincerely, Paul Jackson Rice Chief Counsel;

ID: aiam0438

Dear Mr. Boschetti: We appreciate the opportunity to further discuss the questions yo raised during our visit of June 9 and 10. I will try to answer each question as fully as possible.; 1. It would be unfortunate if the effect of our standards on domesti passenger car production in Europe is to raise costs to the point where significant numbers of people are forced to rely on cheaper and more dangerous vehicles such as motor driven cycles. However, we do not think this result likely in the light of the continuing demand for inexpensive passengers cars and in the absence of legislation by the European nations to compel adoption of the costlier safety features.; 2. We are aware of the concern of foreign manufacturers with th effects of the standards. The National Highway Traffic Safety Administration will attempt to be as flexible as possible, consistent with its mandate to insure the safety of vehicles sold in the United States. The discretion allowed the agency to exempt vehicles from a standard is a matter that Congress will have to decide. At the present time, the exemption authority given the National Highway Traffic Safety Administration by the 1966 Act has expired, and we are therefore unable to agree to any exemptions unless Congress chooses to recreate the exemption authority in some form.; 3. In the development of standards, the National Highway Traffic Safet Administration attempts to evaluate their effects on foreign as well as domestic manufacturers. As you are aware, it is sometimes not possible to reconcile all points of view on a standard, but we would urge you to make every effort to set forth your position on proposed rules during the comment period.; 4,5. Your comments on the proper height for bumpers and the problem o the license plate location have been considered in the context of the rulemaking on Standard No. 215. The amendment issued on June 22, 1971, should serve to lessen the height problem to some degree, and on the basis of present data we regard the height thereby established as reasonable for the overall vehicle population. The shape of the license plate itself is determined by the individual states and is not within our authority.; 6. The crash characteristics which you suggest for a vehicle's fron end seem reasonable, but because they fall beyond the scope of the present rulemaking on Standard No. 215, any consideration of them will have to be deferred. Although we realize that the front seats can supplement the side structure of a car in a side impact, the question as to whether the seats should be retained was considered in the development of the final version of Standard No. 214, and it was determined at that time that the standard would provide a more reliable measure of side strength if the tests were conducted with the seats removed. The National Highway Traffic Safety Administration is still of that opinion, although it would consider any additional information presented in support of a petition to amend the standard to allow retention of the seats.; 7. On the subject of prospective standards, the National Highwa Traffic Safety Administration is currently preparing a new version of the program plan for motor vehicle safety standards. The plan is intended to map the course of rulemaking for the next several years, and should serve to answer most of your questions on timing. We expect to announce the new plan in the very near future.; I hope this letter has been responsive to your questions. If not, or i additional questions arise, do not hesitate to ask us.; Sincerely, Douglas W. Toms, Administrator

ID: aiam4105

Dear Mr. Black: This responds to your letter to Mr. Barry Felrice, our Associat Administrator for Rulemaking, requesting an interpretation of Part 541, *Federal Motor Vehicle Theft Prevention Standard*. Specifically, you stated that Alfa Romeo plans to label its front and rear bumpers in the following locations. The front bumper would have a label attached to the bumper assembly in the area where it would not be visible if a front license plate was attached to the bumper. The rear bumper would have a label attached to the rear bumper in an area that will be covered by a plastic snap-in molding. This molding must be removed to remove the rear bumper from the vehicle. You asked whether these planned locations would satisfy the requirement of S541.5(d)(1)(iii) that the labels be 'visible without further disassembly once the part has been removed from the vehicle.' It is NHTSA's opinion that the locations specified for marking bumpers in your letter would satisfy the requirement of S541.5(d)(1)(iii).; Your planned location for labeling the front bumpers is in an are where those labels will be visible at the time the cars arrive at the dealer and will remain visible unless and until a front license plate is installed on the car. NHTSA must thus determine whether the possible need to remove a front license plate would result in labels in this location failing to satisfy the requirement that labels be placed so that they will be 'visible without further disassembly once the part has been removed from the vehicle.' It appears not to be necessary to remove the front license plate in order to remove the front bumper from your vehicles. Hence, one might conclude that such location would not satisfy this requirement.; However, the intent underlying this requirement was clearly set fort in the rulemaking proceeding that established Part 541. The preamble to the notice of proposed rulemaking contained the following sentence: 'Both commenters agreed, however, that NHTSA's regulations should ensure that investigators will not have to conduct any *additional* dismantling (over and above what chop shops, parts dealers, or thieves have ordinarily done) to locate the identifier on parts removed from a vehicle.' (Emphasis in original) 50 FR 19731, May 10, 1985. NHTSA believes that license plates are routinely removed from front bumpers by legitimate parts dealers prior to reselling the bumper. Law enforcement groups have assured us that license plates are removed from stolen bumpers, so that the stolen part cannot be traced to its rightful owner. In these circumstances, the agency has no reason to believe that labels for front bumpers that are covered by the front license plate will require investigators to conduct additional dismantling of the front bumpers. Accordingly, we conclude that labels on front bumpers that are clearly visible when the front license plate is removed satisfy the requirement that those labels be 'visible without further disassembly once the part has been removed from the vehicle.'; With respect to the rear bumpers, the situation is simpler. Accordin to your letter, the plastic molding covering the labels *must* be removed to remove the bumper from the vehicle. Thus, the label would be visible without further disassembly once the bumper has been removed from the vehicle. As such, it would satisfy the requirement of S541.5(d)(1)(iii).; If you have any further questions or need more information on thi subject, please do not hesitate to contact me.; Sincerely, Erika Z. Jones, Chief Counsel

ID: aiam5423

"Dear Mr. Ziwica: This responds to your request that the Nationa Highway Traffic Safety Administration (NHTSA) determine that a proposed modification to a previously approved antitheft device on the BMW 7 car line constitutes a de minimis change to the device. The proposed modification is to be effective beginning with the 1995 Model Year (MY). As explained below, the agency concludes that the proposed change to the antitheft device is not a de minimis change. In a Federal Register notice dated October 9, 1986 (51 FR 3633), NHTSA determined that the antitheft device installed as standard equipment on the MY 1988 BMW 7 car line was likely to be as effective as parts marking. In assessing whether changes are de minimis, the agency has focused its inquiry on whether the changed device would continue to provide the same aspects of performance as did the device on which the exemption was based. An example of a de minimis change is the substitution of new components for old components, without changing the aspects of performance provided by the device. NHTSA has also determined that adding a new aspect of performance, making an exempted antitheft device even more effective, while leaving the original aspects undisturbed, is a de minimis change. The change from the original BMW MY 1988 antitheft device to the one proposed for the MY 1995 BMW 7 car line does not present a simple case of either substituting new components for old, without changing the aspects of performance provided, or enhancing the effectiveness of an existing device, by adding a new aspect. Instead, the change is more complex, involving not only the addition of a new aspect (monitoring glass breakage), but also the deletion of some original aspects (monitoring the radio and glove box). The agency is uncertain about the net effect of these changes and is therefore also uncertain whether the new modified device would be at least as effective as the original device. Monitoring glass breakage might decrease the likelihood that a would-be thief would ever enter a vehicle. On the other hand, adding this aspect of performance would not necessarily enhance effectiveness of the antitheft device. If a thief were to gain access to the passenger compartment with a slim-jim or other tool, without breaking the glass, no alarm would sound, making the inside compartment vulnerable to theft. Further, no alarm would sound if the thief then tampered with the radio or glove box, individually. NHTSA believes that the necessity for making judgments about the relative effectiveness of new and removed aspects of performance, and the complexity of the issues underlying those judgments, indicate that the changes are not de minimis. Indeed, these judgments are similar to the ones that the agency must make in considering a new petition for exemption. Accordingly, if BMW wishes the planned MY 1995 device to be the basis for a theft exemption, it must submit a petition with NHTSA pursuant to 49 CFR 543.9(c)(2). Please note that the petition for modification must provide the same information or the modified device as is required under 543.6 for a new device. This includes the statement in 543.6(a)(1) that the antitheft device will be installed as standard equipment on all cars in the line for which an exemption is sought. If you have any questions, please contact Barbara Gray or Rosalind Proctor on (202) 366-1740. Sincerely, Barry Felrice Associate Administrator for Rulemaking";

ID: 18773.ztv

Mr. Paul Grundy
General Manager
Safelite
12027 Hesperia Road
Suite D
Herperia, CA 92345

Dear Mr. Grundy:

This is in reply to your letter of August 31, 1998, asking for our opinion on your planned modification to the center high-mounted stop lamp which is Federally-required equipment on passenger cars, light trucks, and vans.

You write that you are familiar with the requirement that the center high-mounted stop lamp must be steady burning in use, but you believe that you have designed your device to comply with this requirement. You inform us that when the brake is applied, your device "will not diminish the Center High-Mounted Stop Lamp (CHMSL) and pulse off and on, but instead will pulse brighter from the continuous burning nature of the CHMSL, twice a second for approximately six seconds, then return to the solid light output of the CHMSL." In our opinion, a pulse that results in either an on/off operation or that varies or modulates the intensity of the light, results in a lamp that is not steady burning in use within the prohibition imposed by Federal Motor Vehicle Safety Standard No. 108.

You have also informed us that you believe you are "adhering to the spirits of the requirements of Standard 108," referencing a July 1989 letter to Robert Knauff which you interpret as opining "that an enhancement feature combining a pulse lamp with a stop lamp is not forbidden under the standard 'as an after-market device . . . if it does not violate the rendering inoperative provision."

The Knauff letter of July 24, 1989, clearly stated that aftermarket equipment intended to replace original equipment must comply with the requirements for original equipment including the specification that stop lamps be steady burning in use. The statement you quote is correct only insofar as it is restricted to aftermarket center high-mounted stop lamps manufactured for use on vehicles that Federal law never required to have them (e.g., passenger cars manufactured before September 1, 1985, and light trucks and vans manufactured before September 1, 1993).

We also would like to confirm that the opinions in the Knauff letter regarding "rendering inoperative" and the applicability of state laws remain in effect today.

If you have any questions, you may call Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref:108
d.11/12/98

ID: 9783

Mr. David A. Scott
President, RKS International L.L.C.
822 Wisconsin Avenue
Racine, WI 53403

Dear Mr. Scott:

This responds to your letter of March 8, 1994, asking for information about this agency's regulations regarding importation and sale of motor vehicles and motor vehicle equipment.

You intend to import "fiberglass kit cars." The cars may be imported "either disassembled or partially assembled." Your company "will then be providing and/or installing American parts in the U.S. for the major mechanical portions like engines, transmissions, suspension systems, tires, etc."

It appears from your letter that you intend to import items of equipment, either individually or as part of a larger assembly, which, after entry into the United States, will have the drive train and related components installed that are necessary to complete its manufacture as a motor vehicle. For purposes of this interpretation, it is unimportant whether the equipment is imported as individual items, or assembled into a vehicle lacking a power train.

Some items of motor vehicle equipment are subject to the Federal motor vehicle safety standards (FMVSS). In order to be imported into the United States, they must comply with all applicable FMVSS. Passenger car equipment that must comply includes brake hoses, brake fluid, lamps and reflectors, tires, glazing material, and seat belt assemblies. It is mandatory that all these items (except lamps and reflectors) bear a DOT symbol in order to be imported; the symbol is the manufacturer's certification of compliance with the FMVSS. It is optional for lamps and reflectors to be marked with the DOT symbol. If they are not marked, permissible options include a certification statement attached to the equipment item or on the container in which the item is shipped.

When assembly of the vehicle is completed in the United States, its assembler must satisfy itself that it conforms to all applicable FMVSS and affix a label certifying that the vehicle complies.

I have enclosed a copy of an information sheet for new manufacturers of motor vehicles and motor vehicle equipment. It identifies relevant Federal statutes and this agency's standards and regulations affecting motor vehicle and motor vehicle equipment manufacturers. It also explains how to obtain this agency's safety standards and regulations. If you have further questions we shall be pleased to answer them.

Sincerely,

John Womack Acting Chief Counsel

Enclosure ref:591 d:4/25/94