Interpretation ID: nht91-1.40

DATE: February 14, 1991

FROM: Anne Lombardi -- Acting Director, Office of Passenger Enforcement and Facilitation, Department of the Treasury

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3-11-91 from Paul Jackson Rice to Anne Lombardi (A37; VSA 102(3) Part 591)

TEXT:

We have Military Customs Advisors stationed around the world who provide information and guidance to Military Customs Inspectors performing preshipment examinations of automobiles and other vehicles. We would appreciate your opinion on a question which was raised by our Advisor stationed at Subic Bay in the Philippines.

Military and DOD civilian employees stationed in that country frequently purchase automobiles which are composites of old chassis and engines, of U.S. manufacture, and new bodies and interiors, fabricated and attached to the chassis by local Filipino car shops. Normally, the chassis and engines were not taken abroad by the importers, but were purchased in the Philippines from other sources. In most cases the chassis are said to have been manufactured prior to January 1, 1969.

The question is simple. Which DOT regulations apply to these automobiles, those applicable to the year the chassis was manufactured, or those applicable to the year the new body is attached?

We are writing to you at the recommendation of the Office of Vehicle Safety Compliance. Additional information, if needed, is available from Sid Allshouse at (202) 566-5607.