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Friday, April 21, 2017

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. 



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