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									DOT Requirements
for the Importation and Certification of
Unconventional Vehicles


             AAMVA Region IV Conference
               Park City, Utah; June 27, 2007
                      Coleman Sachs
       Chief, Importation and Certification Division
      National Highway Traffic Safety Administration

                                                       1
NHTSA Responsibilities
 Issues the Federal motor vehicle safety standards
  (FMVSS)
 These establish minimum performance
  requirements for safety systems and components
  on motor vehicles and for certain items of motor
  vehicle equipment
 Agency also regulates the manufacture and
  importation of motor vehicles and motor vehicle
  equipment items that are subject to the FMVSS

                                                      2
Statutory Basis
 49 U.S.C. § 30112(a)

 No person shall manufacture for sale, sell, offer
  for sale, introduce or deliver for introduction in
  interstate commerce, or import into the United
  States any motor vehicle or motor vehicle
  equipment manufactured on or after the date an
  applicable FMVSS takes effect unless the vehicle
  or equipment complies with the standard and is so
  certified by its manufacturer.
                                                       3
Importation Declaration

 HS-7 Declaration form must be filed with
  U.S. Customs and Border Protection (CBP)
  for motor vehicles and motor vehicle
  equipment items subject to the FMVSS
  imported into the United States.
 Form has 14 boxes, one of which must be
  checked to identify a lawful means for
  importing the vehicle or equipment item
                                             4
5
Equipment subject to the FMVSS

 Tires
 Rims
 Brake Hoses
 Brake Fluid
 Seat Belt Assemblies
 Lighting Equipment
 Glazing

                                 6
Importation Restrictions
 Flat prohibition on the importation of an
  equipment item, new or used, that is subject
  to a standard, unless the equipment is
  manufactured to the standard and is so
  certified
 Nonconforming vehicles can be imported
  provided they are determined eligible for
  importation and are imported by a
  registered importer
                                                 7
Conforming Vehicles (Box 2)
 Vehicles that are originally
 manufactured to conform to all
 applicable Federal motor vehicle
 safety, bumper, and theft prevention
 standards, and bear a label to that
 effect, permanently affixed by the
 original manufacturer, can be imported
 without restriction
                                          8
Certification
 Performed by the manufacturer and not by
  NHTSA
 Manifested by a label permanently affixed
  to the vehicle in a prescribed location
 Identifies the manufacturer, the date of
  manufacture, and the vehicle type
 States that the vehicle complies with all
  applicable FMVSS in effect on the date of
  manufacture shown above                     9
Location of Certification Label
 For passenger cars, MPVs, trucks and buses, the
  label must be in the area of the driver’s door
 For motorcycles, the label must be affixed to a
  permanent member of the vehicle, as close as is
  practicable to the intersection of the steering post
  and the handlebar
 For trailers, the label must be affixed to forward
  half of the vehicle, on the left side
 For equipment, certification is generally shown by
  the letters “DOT” inscribed on the item in a
  prescribed location
                                                     10
Sample Certification Label
       MANUFACTURED BY:
       USA TRAILER MANUFACTURERS, INC.

       September 1997

       GVWR              8,164 KG (18,000 LB)
       GAWR FRONT        4,354 KG (9,600 LB)
       TIRES             11R17.5HC(H)
       RIMS              17.5X8.25HC
       COLD TIRE INFL    827 kPa (120 PSI) SINGLE
       GAWR REAR         4,354 KG (9,600 LB)
       TIRES             11R17.5HC(H)
       RIMS              17.5X8.25HC
       COLD TIRE INFL   827 kPa (120 PSI) SINGLE

       THIS VEHICLE CONFORMS TO ALL
       APPLICABLE US FEDERAL MOTOR VEHICLE
       SAFETY STANDARDS IN EFFECT ON THE
       DATE OF MANUFACTURE SHOWN ABOVE.

       VIN   WMIXXXXXXXXXXXXXX

       TYPE: TRAILER

                                                    11
Procedural Requirements
Before exporting its products to the United States,
  the manufacturer of a conforming vehicle must:

 Identify itself and its products to NHTSA pursuant
  to 49 CFR Part 566 Manufacturer Identification
 Submit VIN deciphering information to NHTSA
  pursuant to 49 CFR Part 565 VIN Requirements
 Designate a U.S. resident as its agent for service
  of process pursuant to 49 CFR Part 551 Subpt D

                                                       12
Registered Importers
 Must modify nonconforming vehicles so that they
  conform to all applicable FMVSS and bumper
  standards within 120 days of entry.
 Must ensure that all outstanding recalls have been
  performed on the vehicles they import
 Must assume the manufacturer’s responsibility to
  provide owners with notification and remedy in
  the event that a safety-related defect or
  noncompliance is determined to exist in the
  vehicle

                                                       13
Off-Road Vehicles (Box 8)
 NHTSA’s jurisdiction is limited to “motor
  vehicles,” defined in 49 U.S.C. § 30102 as
  vehicles driven or drawn by mechanical power
  that are manufactured primarily for use on public
  streets, roads, and highways
 Vehicles that are not manufactured for on-road use
  (such as dirt bikes, race cars, or ATVs) are not
  motor vehicles subject to the Federal motor
  vehicle safety, bumper, or theft prevention
  standards, but may be subject to jurisdiction of the
  Consumer Products Safety Commission and EPA
                                                     14
Exceptions
A nonconforming vehicle can be imported:
 If it is at least 25 years old (Box 1)
 If it is imported for export only and is so
  labeled (Box 4)
 By a nonresident of the U.S., for personal
  use, for up to one year (Box 5)
 By foreign diplomatic or military personnel
  on assignment in the U.S. (Box 6 and 12)

                                                15
Trucks Converted to Motorhomes
 If the conversion is performed before the
  vehicle is sold to its first retail purchaser,
  the converter would be an alterer under
  NHTSA’s regulations, and must certify that
  the vehicle remains in compliance with all
  applicable FMVSS that are affected by the
  alteration
 The converter must affix an additional label
  to the vehicle that contains this certification
  statement                                     16
Trucks Converted to Motorhomes
            (Part 2)
 If the conversion is performed after the first
  retail sale, the converter has no certification
  responsibilities, but must ensure that he
  does not “make inoperative” any device or
  element of design installed on the vehicle in
  compliance with an applicable FMVSS.
 NHTSA can collect civil penalties for
  violations of the “make inoperative”
  prohibition.
                                                17
Kit Cars
 If a vehicle is shipped in a disassembled
  state, but with all components needed to
  assemble a complete vehicle, it is treated for
  importation purposes as a vehicle, and must
  be certified by its manufacturer (i.e., the kit
  supplier) as complying with all applicable
  FMVSS, or 1) be determined eligible for
  importation by NHTSA and 2) be imported
  by a registered importer.
                                                18
Kit Cars (Part 2)
 If a vehicle is shipped without an engine
  and transmission, it is treated for
  importation purposes not as a motor vehicle,
  but instead as an assemblage of motor
  vehicle equipment items, and will be
  allowed to enter, provided all equipment
  covered by an FMVSS (i.e., tires, rims,
  brake hoses, brake fluid, seat belt
  assemblies, lighting equipment, glazing)
  complies with the standard or is removed.   19
Mini-Trucks
  NHTSA applies the following factors in
  determining the admissibility of mini-trucks as
  off-road vehicles:

 Whether they are labeled for off-road use alone;
 Whether they are advertised for off-road use
  alone;
 Whether they are to be sold by a dealer who also
  sells on-road vehicles;
                                                     20
Mini-Trucks (Part 2)
 Whether the manufacturer or dealer will assist the
  purchaser in registering the vehicle for on-road
  use, such as by issuing a manufacturer’s certificate
  of origin (MCO) or statement of origin (MSO);
 Whether the vehicle is used on the road in its
  country of origin.
  NHTSA solicits input from State DMVs on
  whether these vehicles are being registered for on-
  road use; such use is incompatible with the
  declaration made at the time of entry.

                                                       21
Import Statistics (by HS-7 Box #)
Box   2001    2002    2003    2004    2005    2006


2     1.3 mil 1.9 mil 2.3 mil 2.7 mil 3.9 mil 4.4 mil


3     200K    212K    97K     43K     12.6K   11K


8     41K     55K     79K     95K     88K     105K


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Contacts
 Import and Certification Division
       tel: (202) 366-5291
       fax: (202) 493-0073
       e-mail: importandcertification@dot.gov
 Coleman Sachs (Division Chief)
       tel: (202) 366-3151
       e-mail: coleman.sachs@dot.gov
   David Coleman (VIN questions)
       tel: (202) 366-5302
      e-mail: david.coleman@dot.gov
   Dick Merritt (motor scooters and unconventional vehicles)
       tel: (202) 366-5300
       e-mail: dick.merritt@dot.gov

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