If you want to import a vehicle, legally, contact: ImportAVehicle.com

Friday, April 21, 2017

FMVSS - Is There a Need for DOT Approval? - NHTSA

Tires - FMVSS 109 and 110
Another little bit of a tough concept. The DOT doesn't actually approve vehicles or equipment. They set the standards, and guidelines, the manufacturers certify their FMVSS items meet those standards.

DOT does not approve any motor vehicles or motor vehicle equipment items as complying with all applicable FMVSS. That is instead the responsibility of the vehicle or equipment item's original manufacturer.

Ferrari FMVSS label

 For motor vehicles, the certification is provided in the form of a label that is permanently affixed to the vehicle by its original manufacturer, stating that the vehicle complies with all applicable FMVSS in effect on its date of manufacture. For vehicles other than motorcycles or trailers, the label must be affixed to either the hinge pillar, the door latch post, or the door edge that meets the door-latch post, next to the driver's seating position. For motor cycles and motor driven cycles, the label must be affixed to a permanent member of the vehicle, as close as is practicable to the intersection of the steering post with the handlebars, so that it is easily readable without moving any part of the vehicle except for the steering system. For trailers, the label must be affixed to a location on the forward half of the left side of the vehicle, so that it can be easily read without moving any part of the vehicle.

Source: https://icsw.nhtsa.gov/cars/rules/import/FAQ%20Site/pages/page2.html#Anchor-10-55977

Importing a Disassembled Vehicle - NHTSA

Cars.  Car Parts.  Disassembled Cars.  Disassembled Vehicles.  There are of course lots of vehicles illegally imported to the USA as "parts."  We see and hear about them nearly every day.  While it is legal to import a disassembled vehicle, the NHTSA says if there are parts on that disassembled vehicle that don't meet US FMVSS, then they must be removed prior to import into the USA. 

A disassembled vehicle that is shipped without an engine and transmission is treated for importation purposes not as a motor vehicle, but instead as an assemblage of motor vehicle equipment items. Such an assemblage can lawfully be imported into the U.S., provided any equipment included in the assemblage that is subject to FMVSS, but was not originally manufactured to comply with that FMVSS or was not so certified by its original manufacturer, is removed from the assemblage prior to entry into the U.S. Equipment items that are subject to the FMVSS include tires, rims, brake hoses, brake fluid, seat belt assemblies, glazing materials, and lamps, reflective devices, and associated equipment.

If the assemblage is shipped with an engine and power train (even if those components are not installed), it would be regarded for importation purposes as a motor vehicle, and would have to be either manufactured to comply with all applicable FMVSS, and be so certified by its original manufacturer, in the form of a label permanently affixed to the vehicle, or be determined eligible for importation by NHTSA and be imported by an RI or by a person who has a contract with an RI to bring the vehicle into compliance with all applicable FMVSS after importation.
OEM installed AS1 - DOT safety glass as installed in a 1989 Nissan Skyline. If anyone is telling you they had to replace the glass in a modern imported car, they are probably lying. 

The EPA Kit Car policy says that while it is legal to import vehicle parts, if the parts constitute a disassembled vehicle, or an approximate disassembled vehicle, then the parts are considered a motor vehicle.

So while the NHTSA will allow a disassembled vehicle, the EPA doesn't allow a disassembled vehicle. Taking a motor vehicle apart overseas, shipping the parts to the US, and reassembling them as a vehicle is a violation of the Clean Air Act, according to the EPA.  To legally import a vehicle to the US you have to meet NHTSA, and EPA requirements, making a lot of what people say, about the "parts" they import, illegal.  This is another reason that we stick to complete cars, over 25 years old. They are NHTSA exempt, and at 21 years old EPA exempt. 


Saturday, April 15, 2017

CHP 885 - Passenger Car Equipment Requirements 7-06

Passenger Car Equipment Requirements 7-06

All vehicles must meet APPLICABLE FMVSS.   The key word in that sentence being applicable. As in if a vehicle is excluded or exempt from a requirement, then it doesn't need to meet that FMVSS.

Pre 1965 for pollution control devices.This is in conflict with the ARB requirements of 1967 and earlier are exempt.   You have to love multiple conflicting dates on things.

The first line doesn't mention 21 year old vehicles being exempt.  While it is mentioned, it would be an extra step for someone to know this information.   3520-1

If the vehicle is at least 21 years old, there are no EPA compliance requirements upon importation. The age of the vehicle is determined by subtracting the calendar year of manufacture from the calendar year of importation. If the calendar year of manufacture is unavailable, the importer may substitute the model year or year of first registration. For instance, to qualify in 2001, the vehicle must have been manufactured in 1980 or earlier. The vehicle must be in its original unmodified configuration. Vehicles at least 21 years old with replacement engines are not eligible for this exemption unless they contain equivalent or newer EPA certified engines.
No approval or Customs bond is required by EPA. The importer must also prove to Customs, as required, that the vehicle or engine was manufactured prior to EPA regulation. Documents such as a title, or letter from the original manufacturer may be used for this purpose.The importer must file with Customs, upon entry, an EPA Form 3520-1 and declare code "E" on that form.
Speedometer in kilometers is legal.
Nissan Fiagro Speedometer with a MPH overlay. Even though it isn't a requirement, drivers in the US often want a MPH speedo. 

Right hand drive is legal as long as it has a turn signal system, and an outside rear view mirror on the left side is required.  We wonder if they make 1910's-1920's Buicks adhere to these standards.

Sunday, April 9, 2017

California - Register a Vehicle From Another Country - Direct Import

California vehicle registration information for direct import. HTVR 9A.

There is always some confusion on importation and legalization of vehicles. Especially in California, as we have our own EPA called the ARB.  We have to satisfy five different agencies to title and register a vehicle. These five agencies, are :

For Import - Federal Agency
   a) US Customs - Department of Homeland Security
   b) NHTSA - Federal vehicle safety standards
   c) EPA- Federal emissions requirements 40 CFR Part 85

For Registration - State Agency
  Individual State Requirements
    a) Registration requirements - normally some kind of Department of Motor Vehicles
    b) Emissions Requirements - Vary state to state. Some are state run, some are not.

HTVR 9A (NEW 9/2015)

How Do I Register a Qualified Imported Vehicle? 

Imported vehicle registration applications require the same documents shown in the How To: Register A Vehicle From Out-of State (Nonresident Vehicle) (HTVR 09) brochure available at www.dmv.ca.gov.

In addition, the application must include the following forms for:

Customs—Evidence the vehicle has cleared CBP. Evidence is CBP forms 3299, 3311, 3461, 6059, or 7501 stamped or endorsed by CBP.

NHTSA HS7 Form. 

U.S. Safety—Evidence of compliance with FMVSS vehicles 24 years old or newer. Satisfactory evidence is one of the following:
— The federal certification label affixed to the vehicle certifies the vehicle conforms to FMVSS. — A copy of the letter from the manufacturer certifying the vehicle complies with FMVSS and U.S. emissions standards (usually attainable only for vehicles from Canada).
 — A copy of the DOT bond release letter issued by the NHTSA.
 — A certificate of conformity issued by a CARB-licensed laboratory. (this letter of conformity is for emissions requirements. This line is in the wrong section. This should be under Emissions)

Emissions—Evidence of compliance with EPA and California emission standards. Any of the following are acceptable:
— An EPA and California emission label affixed to the vehicle..
— A certificate of conformity issued by a CARB-licensed laboratory. No smog certification is required if this document is submitted for original registration.
— A letter from the manufacturer stating the vehicle complies with FMVSS and U.S. emissions requirements (usually only attainable for vehicles from Canada).


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