Interpretation ID: nht95-1.93

TYPE: INTERPRETATION-NHTSA

DATE: March 8, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Richard J. Kinsey -- Manager, Fuel Economy Planning & Compliance, Ford Motor Company

TITLE: None

ATTACHMT: ATTACHED TO 10/28/94 LETTER FROM RICHARD J. KINSEY TO RICARDO MARTINEZ

TEXT: This responds to your letter requesting our concurrence on a procedure for determining the domestic content and country of origin for foreign-sourced allied and outside supplier components. I apologize for the delay in our response. You stated that you would like to obtain the relevant information from your present purchasing systems rather than by soliciting the information from your foreign suppliers. You stated that both processes will result in the same information, and that you believe requiring your foreign suppliers to respond to requests for information would impose costly and unnecessary burdens on those suppliers.

We are now in the process of completing our response to several petitions for reconsideration of the final rule on domestic content labeling. Your question is sufficiently related to some of the issues raised by the petitions that we believe it should b e addressed in the context of that response, rather than in a separate letter.

We realize, however, that manufacturers and suppliers have an immediate need for guidance regarding the procedures for making content determinations for the 1996 model year. In a recent letter (copy enclosed) to the American Automobile Manufacturers Ass ociation, we advised that NHTSA had decided to give manufacturers and suppliers for model year 1996 the same alternative they had last year, i.e., in lieu of following the required procedures, they may use other procedures that are expected to yield simi lar results. Therefore, your planned approach will not raise any concerns for model year 1996.

I hope this information has been helpful. If you have any other questions or need some additional information in this area, please contact Edward Glancy of my staff at this address or by phone at (202) 366-2992.