Interpretation ID: nht75-5.50

DATE: 10/01/75

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Maslansky; Niles; Dougherty & Boyajian

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of August 31, 1975, in which you ask whether National Highway Traffic Safety Administration (NHTSA) approval is necessary before selling imported inertia switches in this country.

No specific NHTSA approval is required. However, you should be aware of the regulations governing the importation for sale of motor vehicle equipment into the United States. These regulations provide in part that if imported motor vehicle equipment is not certified by the manufacturer as having complied with all applicable Federal Motor Vehicle Safety Standards, upon entry the importer must file a declaration that no safety standards were applicable to the equipment at the time it was manufactured, that the equipment is exempt from applicable safety standards, or that the equipment has been or shortly will be brought into compliance with applicable safety standards (19 CFR @ 12.80(b)).

The NHTSA has issued no safety standards concerning inertia switches in motor vehicle electrical systems. However, the agency recently issued on Advanced Notice of Proposed Rulemaking (40 FR 40853, September 4, 1975) on the subject of motor vehicle electrical system integrity, with the intent of eventually issuing a safety standard in that area.

We hope this information is of assistance. If you have any further questions, please write us.