National Highway Traffic Safety Administration
Office of Vehicle Safety Compliance
REGISTERED IMPORTER NEWSLETTER No. 5
August 30, 1994
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RENEW SOON!
The Government's 1995 fiscal year begins Oct 1, 1994. As you know, your registration must be renewed at this time. If you wish to maintain your registration you need to provide a "Yearly Statement of Registered Importer" in accordance with 49 CFR 592.5(e). Such statement shall affirm that all information submitted in your original application, or amended later, remains correct. You must include a copy of your insurance contract (for remedy of safety-related defects) updated to cover fiscal year 1995. The annual maintenance fee remains $240. PUBLICITY? The agency publishes a list of all REGISTERED IMPORTER names, addresses and telephone numbers for the benefit of the Customs Service and the general public. This is a form of free publicity for those RI's who do contract compliance certification work for personal vehicles, but reportedly has become a source of some annoyance to those who don't. To alleviate such problems, the agency proposes to add designations of the respective RI's willingness to enter into contracts for certification of various kinds of vehicles. We ask your cooperation in providing relevant information (on the enclosed form) for this purpose. We recognize that some RIs would not want to work on motorcycles or buses for example. Others would not agree to work on anything but cars or vans certified for sale in Canada. Still other RIs do not wish to undertake contracts for certification of any personally owned vehicles. Based on your input, we will commence to report these facts so you will not be bothered by unwanted inquiries in the future. Please complete the enclosed RI business interest checklist form and return it at your earliest opportunity. Such expression of business interest does not relieve an RI of his or her responsibility to maintain shop capabilities for modifications plus repair of safety-related defects, to maintain current copies of the Federal motor vehicle safety standards in the facility, and to maintain a secure storage capability for the vehicles. FURTHER GUIDANCE FOR Some helpful information for those who prepare eligibility petitions was provided in RI Newsletter Nos. 1 and 3. More recent experience has shown a need for further guidance in some areas as described below. In order to write an acceptable petition you will need to become familiar with and responsive to the petition regulation (49 CFR 593) and the technical details of applicable Federal motor vehicle safety standards. For FMVSS 208, petition must contain detailed descriptions of the restraint system at each designated seating position in the vehicle. Information must include both as-built configuration and |
modifications
required to fully comply. Be sure to
cover requirements for passenger side
air bags where applicable (also see RI
Newsletter No. 1)
Whenever petitioning for a vehicle which is not substantially similar to a U.S. certified vehicle of the same model year you must substantiate in great detail its capability to conform to performance criteria of FMVSS 208, 214 and 301 as applicable unless substantiation is obtained from the original manufacturer, the RI must submit test data with the petition (see RI Newsletter No. 3 for details). Whenever a petition is based upon examination of the uncertified vehicle, the agency must know all relevant identifying information. This can be satisfied by attachment of the HS-7 to the petition (you must always submit a copy of each contract within 5 days after signature -- see RI Newsletter No.1). If you do not have a sample vehicle in your possession, the petition must explain the relevant circumstances. Whenever you are notified that one of your petitions is incomplete, you should correct and resubmit the entire petition with a new date and signature (with reference to the petition number assigned by NHTSA) to facilitate further processing. As a minimum, minor revisions may be accomplished by substitution of a completely new page for the original erroneous page (pages should be consecutively numbered). Be aware of the risk involved if you proceed to modify a vehicle while its eligibility petition is under consideration. In the event your petition is denied, the vehicle will have to be exported or destroyed under Customs supervision regardless of how much time and effort you may have invested in it. The surety will also be notified of its potential liability under the bond. ADDITIONAL ELIGIBILITY Attached import eligibility list update (revised 8/5/94) contains all the eligibility determinations issued since publication of the agency's 2nd ANNUAL ELIGIBILITY LIST and supersedes the previous update. The additional eligibility determinations are based upon petitions submitted by RIs which have been granted and published in the Federal Register. Additional eligibility determinations are issued at irregular intervals. The following enclosures were included with the newsletter mailing and are available from George Entwistle (telephone number shown below). Supplemental Eligibility List dated August, 5, 1994 RI Business Interest Checklist dated August 23, 1994 All questions concerning this newsletter should be directed to George Entwistle, 202-366-5306. |