Interpretation ID: nht89-3.34

TYPE: INTERPRETATION-NHTSA

DATE: NOVEMBER 7, 1989

FROM: JOSEPH PERRY

TO: STEPHEN P. WOOD -- OFFICE OF CHIEF COUNSEL, NHTSA

TITLE: IMPORTING A KIT CAR

ATTACHMT: ATTACHED TO LETTER DATED 4-9-90 TO JOSEPH PERRY FROM STEPHEN P. WOOD; (A35; IMPORT REG.) TEXT:

I would like to inquire as to the rules and regulations pertaining to the importing of a kit car. I have been in contact with the manufacturer in England and have been told that they will supply certification that the windshield supplied with the kit wi ll be in accordance with the most recent DOT specification, I believe that it complies with SA1. The other problem area with kit cars appears to be the lights. I plan on using only parts which will be purchased in the U.S. The drive train: engine, clu tch and gearbox, as well as all other parts from a 1987 Ford Mustang which are required to meet EPA regulations will be installed on the car during assembly.

The body chassis unit, possibly two boxes of used and reconditioned suspension parts (Ford Cortina MK III or IV) and interior seats and trim in other boxes. I would like to know if it is acceptable to have all window glass and doors fitted to the body u nit before shipping to best assure its arrival in one piece. The doors which are used with this car are standard production Ford and are usually fitted at the factory on all kits sold.

I believe the question that I require answered is: Will fitting the windows and doors to the body unit be considered an acceptable assembly to import a car kit? As the interior, suspension, dash, wiring and steering and wheels will not be installed.

Thank you for any assistance and information that you might be able to give me.