Interpretation ID: aiam4262
90 Horace Street
Startford
CT 06497;
Dear Mr. Cameron-Nott: This is in reply to your letter of December 7, 1986, with respect t kit cars. Your first question concerns a 1965 Jaguar that has been rebodied but carries its original mechanical components, title, and identification number. The National Traffic and Motor Vehicle Safety Act does not require conformance with the Federal motor vehicle safety standards applicable to passenger cars if the passenger car to be imported into the United States was manufactured before January 1, 1968. However, certain of these standards cover vehicle components, and if the relevant components have been manufactured on or after January 1, 1968, these components would be subject to the applicable Federal safety standard. These components include brake hoses, lighting equipment, tires, retreaded tire, glazing materials (most importantly, the windshield must be marked AS-1), seat belt assemblies, and wheel coves (which may not incorporate winged projections). Although the 1965 Jaguar would have a new body, by retaining its original mechanical components, title, and identification number, it would be considered a 1965 model and not subject to the Federal motor vehicle safety standards applicable to passenger cars. But if any of the equipment listed above has been manufactured after January 1, 1968, those items must comply in order to be imported into this country.; You have asked how the situation would differ were the bodied Jaguar 1972 model, the other facts being identical. We would consider this car a 1972 model, and required to conform to all Federal motor vehicle safety standards that applied on the date of its original manufacture. Conformity could be achieved either before or after its importation into this country.; Your second question concerns 'a kit car consisting of both new an used components i.e. new body/chassis and used mechanicals from various sources including Ford/Triumph and M.G.' You have reported EPA's position that the year of the engine determines what standards are to be met, and you have asked if these are also DOT's requirements. The age of the engine is not the determining factor with us. Generally, the agency considers a kit car consisting of new body and new chassis to be a new motor vehicle, and required to meet all Federal motor vehicle safety standards applicable to new passenger cars as of the date of its assembly, even if some of its mechanical components have been used previously. This means that such components must not prevent the assembled vehicle from meeting those standards.; If you have further questions we would be pleased to answer them. Sincerely, Erika Z. Jones, Chief Counsel