Interpretation ID: 17331.ztv

Angela Dyer, Company Secretary
Broomstick Cars Limited
Willow Farm
Ivinghoe
Aston Leighton Buzzard
Bedfordshire LU7 9DG
England

Dear Ms Dyer:

Forgive my delay in replying to your letter of 4th February 1998, regarding the possible importation into the United States of a Jaguar XK120 replica "as a vehicle over 25 years old."

According to your letter, the car has "a new chassis and GRP body panels, but most of the parts are from the original car. These include engine, gear box, suspension, steering, transmission and axles." You have explained that the original car is a "Jaguar S type over 25 years old."

Under 49 U.S.C. 30112(b)(9), "a motor vehicle that is at least 25 years old" may be imported into the United States without having to comply with the Federal motor vehicle safety standards. Although the Jaguar XK 120 replica is composed partly of parts that may be over 25 years old, the car's age is computed as of its date of its manufacture. Thus, a replica assembled in 1998 is not "a motor vehicle that is at least 25 years old" and it cannot be imported into the United States under Sec. 30112(b)(9).

Sincerely,
John Womack
Acting Chief Counsel
ref:591
d.5/13/98