Interpretation ID: 17569.ztv

Mr. Peter Borne
SuperHero Cars Ltd.
6336 Humboldt Ave. S.
Richfield, MN 55423

Dear Mr. Borne:

This will confirm that we regard as a 1971 motor vehicle the Bat-Mobile you described in your letter of March 12, 1998, as follows:

This is a custom built fiberglass molded body, which has been mounted to a 1971 Chrysler New Yorker Frame. All the running gear and mechanical elements are 1971. The engine . . . has been replaced by the same 1971 Vintage Chrysler 440. This car is registered in Vancouver B.C. as a 1971 New Yorker.

You may import this vehicle pursuant to the declaration that the vehicle is 25 or more years old, which means that it does not have to be brought into conformity with the Federal motor vehicle safety standards. However, this exemption does not apply to those items of equipment which are the subject of certain individual Federal motor vehicle safety standards. These items are brake hoses and brake fluid, lighting equipment, tires, glazing, and seat belt assemblies (if the Bat-Mobile is equipped with them). These items of equipment must conform in order to be imported. Generally, conformance with our requirements is indicated by the DOT symbol which the manufacturer has placed on the item to certify compliance.

We are unable to advise you on the requirements of the Environmental Protection Agency for exceptions to the emissions regulations.

If you have any further questions, you may call Taylor Vinson of this Office who spoke with you on April 16 (202-366-5263).

Sincerely,
John Womack
Acting Chief Counsel
ref:591
d.5/14/98