Interpretation ID: aiam3879
Answer Products
Inc.
27967 Beale Court
Valencia
CA 91355;
Dear Mr. Cole: This responds to your letter regarding the importation of motorcycl helmets by your company from Italy.; Federal Motor Vehicle Safety Standard No. 218, *Motorcycle Helmets* applies to helmets designed for use by motorcyclists and other motor vehicle users. You stated in your letter that there is a DOT *approval sticker* on the helmet and that your company's name is clearly displayed on the helmet. Standard No. 218 requires that each helmet be permanently and legibly labeled with the manufacturer's name or identification, model designation, size, month and year of manufacture, and the symbol DOT. The DOT symbol does not indicate approval of any helmet by the Department of Transportation. Instead, the DOT symbol represents the manufacturer's certification that the helmet meets all the requirements of Standard No. 218. A copy of this standard is enclosed for your information.; As an importer, your company is also considered a manufacturer unde the provisions of the National Traffic and Motor Vehicle Safety Act which is administered by this agency. Therefore, either your company's name or the Italian manufacturer's name should be affixed to each helmet. Your company and the Italian manufacturer are both responsible for any defect in the helmet or failure to comply with the standard's requirements.; You asked about other regulations of which you should be aware. Copie of these are enclosed:; >>>49 CFR Part 551--*Procedural Rules* (Subpart D-- Service of proces on foreign manufacturers and importers).; 49 CFR Part 566--*Manufacturer Identification*.<<< If you need additional information, please contact this office. Sincerely, Frank Berndt, Chief Counsel