Interpretation ID: nht94-2.63

TYPE: INTERPRETATION-NHTSA

DATE: April 29, 1994

FROM: William L. Blake

TO: United States Department Of Transportation

TITLE: Re: 1985 Mercedes Benz, Model 280SL, Seriel NO. WDB1070421A026883

ATTACHMT: Attached To Letter Dated 6/9/94 From John Womack to William L. Blake (A42; PART 581; 591; CSA 5106) And Letter Dated 5/11/94 From William Blake To U.S. DOT

TEXT: Gentlemen:

Please be advised that I represent the owner of the foregoing vehicle. I am advised that this vehicle was manufactured and assembled in Europe and shipped to the United States, modified slightly, and then sold. Modification did not include removal o f, or modification of, bumpers to conform to United States crash standards.

The bumper of this vehicle has now been damaged. My client placed a claim with his insurance company, and the insurance company insists that the vehicle can be repaired with parts which were allegedly illegally imported. The reputable body shop to w hich my client took the vehicle indicates that it is illegal to import bumper parts which do not conform to United States crash standards and that accordingly the entire bumper must be replaced in order to conform to United States safety standards.

Please advise as to the following:

1. As to whether it is or is not illegal to import European bumper parts for these so-called gray model vehicles.

2. As to whether it is or is not illegal for an owner to participate in the installation of bumper parts which do not conform to United States standards.

2

Please refer me to the appropriate statutes and/or regulations relative to the foregoing.

Thank you very much for your cooperation.

Yours very truly,