Interpretation ID: 21324.ztv

Mr. Kenneth J. Sailor
2 Oaks Road
Shiplake
Henley on Thames
Oxfordshire RG9 3JH
England

Dear Mr. Sailor:

This is in reply to your letter of February 11, 2000, informing us of your plans to import "an assemblage of parts" intended to restore a 1979 Caterham Seven sports car.

The parts to be imported would not include the engine and transmission. We note also that the assemblage would not include the following parts that are themselves subject to the Federal motor vehicle safety standards (FMVSS): brake hoses, brake fluid, glazing, seat belts, headlamps, "taillight assemblies," turn signals, side marker lamps, and reflectors. You will also "fit DOT certified tires to the wheels." You have asked us for a letter stating that the "assemblage of parts being imported is not subject to DOT requirements."

You have not mentioned other motor vehicle lighting equipment such as stop lamps, parking lamps, backup lamps, and license plate lamps. If the Caterham Seven was equipped with these items of lighting equipment (you may have included stop lamps in the phrase "taillamp assemblies"), these items also must be removed from the assemblage if they have not been certified to comply with FMVSS No. 108, Lamps, Reflective Devices and Associated Equipment. Then, the individual equipment items remaining on the assemblage of parts as you have described it will not be subject to any of the FMVSS.

If you have any questions, you may call Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:591
d.3/27/00