Interpretation ID: 2393y
27 Shady Lane
Nashua, NH 03062
Dear Mr. Perry:
This is in reply to your letter with respect to the rules and regulations pertaining to the importation of a kit car. Your letter indicates that the vehicle will utilize both new and used components, some of them imported from England, and the remainder supplied in the United States. I regret the delay in responding.
Specifically, the components you wish to import from England are described as "the body chassis unit, possibly two boxes of used and reconditioned suspension parts and interior seats and trim in other boxes." You would like to know "if it is acceptable to have all window glass and doors fitted to the body unit before shipping to best assure its arrival in one piece; at this point "the interior, suspension, dash, wiring and steering and wheels will not be installed."
Under the fact situation you outline, it is immaterial under our regulations whether or not you install the window glass and doors before shipping, or after importation into the United States. If you prefer to install these components before shipping, that is acceptable to us. Those components, such as windshield glazing, that are covered by an applicable Federal motor vehicle safety standard must comply with such standard upon importation, whether or not they are attached to a larger assemblage of motor vehicle equipment. With respect to windshield glazing, the manufacturer's marking of "ASl" and "DOT" will provide the necessary assurance to a Customs inspector that the glazing conforms.
Although you mention no other covered equipment except lighting, if you are importing as part of the kit brake hoses, brake fluid, tires, seat belt assemblies, or other glazing for use in the vehicle, these must also be marked as conforming with DOT requirements.
If you have any further questions, we shall be happy to answer them
Sincerely,
Stephen P. Wood Acting Chief Counsel ref. Import d:4/9/90