Interpretation ID: 1983-1.31

TYPE: INTERPRETATION-NHTSA

DATE: 03/21/83 EST

FROM: FRANK BERNDT -- CHIEF COUNSEL, NHTSA

TO: HOUTAN MOSTAGHIM -- VICE PRESIDENT, PAN UNITED INC.

TITLE: NOA-30

ATTACHMT: MEMO DATED 3-4-83, FROM HOUTAN MOSTAGHIM, TO NHTSA, REF: PUI 109/383, TITLED DOG CLIP

TEXT: This responds to your letter of March 4, 1983, asking whether there are any Federal regulations applicable to an accessory component used to secure pets to vehicle seat belts. The component latches into the seat belt buckle and is then attached to the pet's collar or leash. Your company intends to import these accessories.

There are no Federal motor vehicle safety standards or regulations applicable to the product you describe. Therefore, as far as this agency is concerned, there are no responsibilities you must meet prior to importing this item (i.e., there are no testing or licensing requirements). You should, however, contact State authorities to determine if they have any licensing requirements or regulations that would be applicable to the sale of such a device.

You will have to contact private counsel to determine the product liability implications and insurance needs of your enterprise.

Thank you for your inquiry.