Interpretation ID: nht92-2.34

DATE: November 12, 1992

FROM: P.R. Smorra -- Group Vice President, Chrysler Corporation

TO: Administrator -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 2/9/93 from John Womack to Patrick R. Smorra (A40; Part 555)

TEXT:

Chrysler Corporation is considering a program in which a foreign national could purchase a Chrysler vehicle through a dealer in their country but take delivery of it in the United States so they could use it while on vacation in the States. At the conclusion of their vacation the vehicle would be shipped to them in their home country.

In order to implement this program and export a Chrysler product which is certified in our customer's home market the vehicle would not comply with all U.S. regulations (including EPA and FMVSS). Chrysler International is requesting a variance to these vehicle requirements for the purpose of temporary use by our vacationing customers.

Chrysler has been very aggressive in relaunching our international efforts over the past five years. In 1993 we expect to sell over 100,000 vehicles overseas. We are confident that this program will further contribute to our international growth.

Please advise me if you require additional information in order to grant this variance. Relative to this variance, please clarity two issues: If, upon the expiration of the variance, the vehicle has not left the U.S., who is responsible for the delinquency? In the unlikely event that this vehicle has an accident in which it is deemed undriveable, who is responsible for its disposition?

Thank you for your consideration. I look forward to your reply.