Interpretation ID: aiam1797
Great Dane Trailers
Inc.
Lathrop Avenue
P.O. Box 67
Savannah
GA 31402;
Dear Mr. Blewett: This responds to your January 8, 1975, request for confirmation tha air-braked trailers built after January 1, 1975, for export to Mexico (and therefore without brake systems conforming to Standard No. 121, *Air brake systems*) may re-enter the United States on a continuing basis on railway cars for marshalling and unloading. Your letter states that the trailers would not be used in interstate commerce, by which we understand they would not operate on public streets or highways.; The NHTSA would not consider this limited introduction of non-complyin trailers into the United States an importation or introduction into interstate commerce for purposes of S108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1397). This means that the trailer could legally be brought into the United States on a railway car to be unloaded on private property and returned by railway car to Mexico. These vehicles could not be operated on the public highway without violating S 108(a)(1)(A). I enclose a copy of a letter on this subject for your information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel