Interpretation ID: nht89-1.81

TYPE: INTERPRETATION-NHTSA

DATE: 04/27/89

FROM: P.H. Moes -- U.S. Trade Corp.

TO: Chief Counsel, NHTSA

TITLE: INTERPRETATION CAFE-REGULATIONS: OBLIGATIONS & RESPONSIBILITIES

ATTACHMT: ATTACHED TO LETTER DATED 06/22/89 FROM STEPHEN P. WOOD -- NHTSA TO P.H. MOES; REDBOOK A33; CSA 502 (9); CSA 505

TEXT: Dear Sir:

US Trade Corporation has been converting vehicles for their owners for many years.

We assisted with the importation and filled out the short form or HS-189 and HS-7 forms as per copies enclosed. The name of the importer is always the owner of the vehicle.

However, when an EPA-emission conversion has to be done as well, the EPA entry form 3520-1 will show our Company as the importer of record.

Some US Customs officers are now confused and sometimes require the customs broker to fill in the name of US Trade Corporation instead of the owner on the DOT forms.

We understand that the only vehicles that we have to list on the yearly CAFE form are the ones that we import with US Trade Corporation listed as owner.

In order to clarify this confusion, we would like to receive your confirmation on both issues on writing so that we can inform our brokers accordingly and know what to do with the CAFE form.

Sincerely,