Interpretation ID: 2633y
P.O. Box 3571
Agana, Guam 96910
Dear Mr. Cepeda:
This is in reply to your letter of July 24, l990, to Frank Berndt, the former Chief Counsel of this agency. You wish to import 8 to 12 stainless steel parts. After importation, the parts would be put together to form a Jeep body. Ultimately, an engine, chassis, and all other parts, which are from Guam, would be added to form a completed motor vehicle.
You have asked for confirmation that "the stainless steel jeep body is not a motor vehicle and is not required to meet any provision of the U.S. 49 CFR Part 400 to 999." Apparently, you are having a misunderstanding with Guam Customs on this point.
We are pleased to provide confirmation of your interpretation. There are no Federal motor vehicle safety standards that apply to the stainless steel body parts that you describe. This means that you may import them, as individual body parts, into Guam without violating the National Traffic and Motor Vehicle Safety Act. Under 49 CFR 591.5(i)(2), the appropriate declaration for entry is that they were manufactured on a date when no Federal motor vehicle safety standards were in effect that applied to them.
Sincerely,
Paul Jackson Rice Chief Counsel ref:59l d:8/29/90