Interpretation ID: nht93-5.16

TYPE: Interpretation-NHTSA

DATE: July 8, 1993

FROM: Harold R. Burke, Esq. -- Duel and Holland

TO: Office of the Chief Counsel, NHTSA

TITLE: Importation of type M-151 military vehicle

ATTACHMT: Attached to letter dated 3/16/94 from John Womack to Harold R. Burke (A42; Part 591; VSA Sec 571.7(a))

TEXT:

At the suggestion of Mr. George Shifflett, I am contacting you with respect to the importation of approximately 8,000 type M-151 military vehicles ("Jeeps") originally built in the United States between 1973-75. These vehicles have never been used and are currently located outside this country. It is my client's intention to return these vehicles to the United States and resell them for use here. Specifically, my client requests a legal opinion as to the following questions:

1. As U.S. origin vehicles which have been outside this country since 1975 are they now classified as "foreign" vehicles which are subject to current D.O.T. and E.P.A. safety and emissions criteria?

2. If they are not considered "foreign" vehicles what, if any, D.O.T. regulations would apply to the registration of such vehicles for use on U.S. roads?

3. If they are considered "foreign" vehicles what, if any, D.O.T. regulations would apply to the registration of such vehicles for use on U.S. roads?

If I can provide any additional information with respect to these questions, please feel free to contact me.

Thank you and your earliest reply will be appreciated.