Interpretation ID: aiam3416
Vice President
Superior Pontiac
Inc.
5201 Camp Road
Hamburg
NY 14075;
Dear Mr. Izzo: This responds to your letter of March 25, 1981, regarding Safet Standard No. 127, *Speedometers and Odometers*. You ask whether paragraph S4.1.4 of the rule, the 'highlighting' requirement, would be satisfied by placing a sticker bearing the number '55' in the appropriate location on the outside of the glass covering the speedometer. You were previously informed by agency staff that it is necessary to put the sticker inside the glass in order to comply with the standard. In a subsequent phone conversation with Joan Griffin of my office, you stated that you are importing new and used vehicles from Canada.; The information you received earlier is incorrect. As the term is use in paragraph S4.1.4 of Standard No. 127, 'highlighting' refers to any method of placing emphasis on the numeral '55' so that it stands out from the other numerals on the mph scale. The standard does not specify how this is to be accomplished. Thus, it is not necessary for you to place the '55' sticker on the inside of the speedometer glass to comply with the standard. It will suffice if you put the sticker on the outside of the glass. However, we would prefer it if you put the sticker inside the glass, since it then would be more difficult to remove the sticker from the vehicle.; In your conversation with Ms. Griffin, you asked whether the use vehicles that you import from Canada must be brought into compliance with the Federal motor vehicle safety standards before they can be brought into the country. Used vehicles that are imported into the United States must be brought into compliance with all Federal safety standards in effect at the time of manufacture. However, the vehicles do not have to be brought into compliance *before* they are imported. Nonconforming vehicles may be imported if the importer executes a bond for the value of the vehicles and brings the vehicles into compliance with all applicable standards within 120 days of the date of importation.; We hope you find this information helpful. Please contact this offic if you have any questions.; Sincerely, Frank Berndt, Chief Counsel