Interpretation ID: 22222.jeg

Mr. Andrew P. Doornaert
Arthur Andersen LLP
Suite 2700
500 Woodward Avenue
Detroit, MI 48226-3424

Dear Mr. Doornaert:

This responds to your letter requesting an interpretation of Part 583, Automobile Parts Content Labeling. You asked for clarification concerning how the value of certain "minor items" is treated in making various content calculations. Your questions are addressed below.

You first asked about 583.6, Procedure for determining U.S./Canadian parts content. Paragraph 583.6(c)(4)(iv) of this section provides that "(f)or the minor items listed in the 583.4 definition of 'passenger motor vehicle equipment' as being excluded from that term, outside and allied suppliers may, to the extent that they incorporate such items into their equipment, treat the cost of the minor items as value added in the country of assembly." You noted that, as a result of a recent amendment to Part 583, the list of minor items once included in 583.4 is no longer there. However, the same list now appears in 583.6(a). The list is comprised of the following items: nuts, bolts, clips, screws, pins, braces, gasoline, oil, blackout, phosphate rinse, windshield washer fluid, fasteners, tire assembly fluid, rivets, adhesives, grommets, and wheel weights.

You are correct that we did not intend to change the provision permitting outside and allied suppliers to treat the cost of these minor items as value added in the country of assembly. We plan in the future to issue a technical amendment to correct this now-obsolete cross-reference.

You also asked whether the minor items provision of 583.6 can be considered in determining the country of origin for components of engines and transmissions in 583.8(c). While the minor items provision of 583.6 does not technically apply to the determinations made in

583.8, we nonetheless conclude that suppliers of engines and transmissions may treat the cost of these minor items as value added in the country of assembly for purposes of 583.8 determinations. The National Highway Traffic Safety Administration adopted the minor items provision of 583.6 to avoid imposing on suppliers the unnecessary burden of having to obtain content information about minor items whose value was so small as to be unlikely to have any effect on overall content calculations. This rationale is equally applicable to 583.8 determinations.

I hope this information is helpful. If you have any further questions, please call Edward Glancy of my staff at (202) 366-2992.

Sincerely

John Womack
Acting Chief Counsel

ref:583
NCC-20:EGlancy:mar:3/21/01:62992:OCC 22222
cc: NCC-01 Subj/Chron, Redbook (2), interp 583
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