Interpretation ID: nht90-4.7

TYPE: Interpretation-NHTSA

DATE: September 14, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: John Durant -- Commercial Rulings Division, U.S. Customs Service

TITLE: None

ATTACHMT: Attached to letter dated June 26, 1989 from S.P. Wood to M. Turner; Also attached to letter dated 6-28-90 from J. Durant to P.J. Rice (OCC 4965); Also attached to letter dated 5-1-90 from J. Laderberg to J.H. Heinrich

TEXT:

Thank you for your letter requesting our views on whether a Customs Service requirement that "all imported automotive glass for the replacement market be permanently marked with the name of the country of origin" would in any way impact on the marking re quirements of our agency. As discussed below, we do not believe that such a requirement raises any concerns with respect to our marking requirements.

Federal Motor Vehicle Safety Standard No. 205, Glazing Materials (49 CFR S571.205), sets forth certain marking requirements. The primary purpose of these requirements is to help this agency identify the actual manufacturer of the glazing material for th e purpose of defect and noncompliance recall campaigns. I am enclosing for your information a copy of a letter dated June 26, 1989, sent to Diamond-Star Motors, which discusses Standard No. 205's marking requirements.

According to your letter, the purpose of the Customs Service marking requirement would be to make an automobile owner aware of the country of origin of the imported glass. Thus, such a requirement would serve a different purpose than our requirements. It is our opinion that marking glass with the country of origin would not cause any confusion with respect to the markings required by Standard No. 205, nor raise any other concerns with respect to our marking requirements.

If you have any further questions or need any additional information about this topic, please feel free to contact Ms. Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.