Interpretation ID: nht87-3.42

TYPE: INTERPRETATION-NHTSA

DATE: 12/10/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Interworld Commodities, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Isaiah Herman President Interworld Commodities, Inc. 15 West 44th Street New York, NY 10036

Dear Mr. Herman: This is in reply to your letter of October 13, 1987. One of your clients "plans to purchase a Corporation Stretched Limousine" to be shipped to Japan, and would like "to obtain the standards and regulations for the modifications that are done to the vehi cle". The car in question is a Lincoln Town Car.

We understand that the Lincoln Town Car is available from several converters in a lengthened, or "stretched" version. We further understand from a conversation that you had with Taylor Vinson of this Office that your clients intend to purchase the vehicl e and have it converted after title passes to them. The converter is subject to the restriction that it must not render inoperative in whole or in part any device or element of design installed in accordance with a Federal motor vehicle safety standard. This restriction applies regardless of the future use or location of the vehicle. However, the Federal motor vehicle safety standards do not apply to new and untitled vehicles that a manufacturer intends for export, and if the alterations to a car owned by your clients resulted in noncompliances we would regard this as only a technical violation of the restriction provided that the vehicle were shipped to japan immediately following the modifications.

I hope that this answers your questions. Forgive our delay in replying to you.

Sincerely,

Erika Z. Jones Chief Counsel

10/13/87

Ms. Erika Jones Office of the Chief Council NHTSA Room 5219 400 7th Street S.W. Washington D.C. 20590

Dear Ms. Jones,

I was told today via one of your staff that you can be of assistance. I have a client who, has plans to purchase a Corporation Stretched Limousine to be shipped to Japan.

They would like to obtain the standards and regulations for the modifications that are done to the vehicle. If there are none please be kind enough to send a letter stating that fact.

I further understand Code of federal Regulations Volume 49 CRF 500 Series would be helpful. Please indicate where to obtain the regulations and any other standards. They are considering purchasing a Lincoln Town Car.

Thank you

Sincerely,

Isaiah Herman

President