Q&a: How To Import, Legality.

[HarrisRacing]

Section 101-45.4901-97 - Standard Form 97, The United States Government Certificate to Obtain Title to a Vehicle.

Buyers of motor vehicles will receive a GSA Form 27A, "Purchaser's Receipt and Authority to Release Property," and a Standard Form (SF) 97-1, "The United States Government Certificate To Obtain Title To A Vehicle." SF 97-1 is not a title; it is evidence of title only for authority to obtain title at the Department of Motor Vehicles(DMV) to a vehicle by the purchaser. Buyers of property other than motor vehicles will receive only the GSA Form 27A. Unless otherwise provided in the Invitation, title to the property sold hereunder shall vest in the Purchaser as and when removal is effected.

The Certificate to Obtain Title in no way serves as a waiver for payment of registration fees, nor county or State taxes assessed to the vehicle, subsequent to its purchase. The Certificate to Obtain Title will only be issued after the vehicle is paid for.

The Certificate to Obtain Title that accompanies vehicles may identify the vehicle as Salvage or Scrap, meaning the vehicle is not intended for driving and its condition is poor and/or it is not road-worthy in its present condition.

These provisions may also be applied to certain accident-damaged vehicles. The type of title issued will be determined at the discretion of each state�s Department of Motor Vehicles (DMV).

Any property listed in the sales catalog "For Export Only" may not be entered into the commerce of the United States and must be exported under conditions described in the sales catalog/brochure. A representative sample from large, commercial quantity “Export Only” lots (greater than ten cartons) may be released to the Purchaser upon full payment if the sample is available at the sales center.

All Purchasers are responsible for complying with all applicable federal licensing and permit regulations prior to exportation. The failure of the purchaser to obtain necessary licensing will not result in the return of any monies tendered for the goods.

The Contractor shall provide a copy of the required procedures for export, when available from the Government, to the Purchaser at the time of final payment. Unless a different period for removal is applicable with respect to goods or conveyances that are sold "For Export Only," the purchaser will have 60 days from auction day to remove the property from the United States or purchaser will be deemed in default and the property will be resold by the Government as provided in paragraph 23 of these Terms and Conditions of Sale.

All forms required for exportation may be obtained at a nominal cost from the U.S. Government. Because of the complexity of some export requirements, the purchaser may wish to secure the services of a Customhouse Broker, bonded carrier, or other professional in securing the necessary documents required for exportation. The Contractor will offer no assistance whatsoever.

SALE OF GOVERNMENT PROPERTY GENERAL SALE TERMS AND CONDITIONS

24. REQUIREMENTS TO COMPLY WITH APPLICABLE LAWS AND REGULATIONS:

It is the Purchaser’s responsibility to ascertain and comply with all applicable Federal, State, local, and multi-jurisdictional laws, ordinances and regulations pertaining to the registration, licensing, handling, possession, transportation, transfer, export, processing, manufacture, sale, use, or disposal of the property listed in the sales catalog.

The Purchaser or user of this property is not excused from any violation of such laws or regulations either because the United States is a party to this sale or has had any interest in the property at any time.

Winning bidders, who pay in full, will be notified by VSE Corporation when they can schedule an appointment to pick up their vehicle(s) - It will be AT LEAST A WEEK from the time of payment before the vehicle is ready for pick up. You will have 60 days from the time you are notified the vehicle is ready for pick up to remove the property. Please contact the storage location to confirm a removal appointment.

The title document (SF-97) will be mailed directly to the buyer once it has been signed by the Treasury Department. If the vehicle has not been removed by the deadline, it will be placed in the next available auction and money will not be refunded.Call 888-534-2828 if you have any questions.

Please go to http://www.cbp.gov/xp/cgov/trade/basic_trade/ for detailed export information. Export Documents are the buyer’s responsibility. VSE does not provide Export Documents. Vehicles will only be released to licensed bonded couriers with a completed CBP 7512 form.

You are doing it again.

I went ahead and struck through everything that you posed that was posted as basically a disclaimer from an auction site. I left what is US law.

Everything you have posted is "to import a car" and the laws for such. "owning a car that..." has not been covered by you whatsoever other than pure speculation.

Edited April 17, 2015 by HarrisRacing

[HarrisRacing]

Sorry I meant to strikethrough the entire thing.

ALL of it include disclaimers from auction sites. They are not law enforcement nor are these laws.

[Matvei27]

SF-97 does not legalize a car. I already explained this to you. It's a temporary title.

Why don't you call the NHTSA and EPA like I told you? Are you afraid of something? I thought your car was legal, right?

Your car was not imported legally therefore it is not legal to own. You just want to pick and chose and think the law doesn't apply to you.

SF 97-1 is not a title; it is evidence of title only for authority to obtain title at the Department of Motor Vehicles(DMV) to a vehicle by the purchaser.

Where exactly does this say your car is now EPA and FMVSS (NHTSA/DOT) exempt?

Nonconforming vehicles less than 25 years old entering the United States must be brought into compliance, exported, or destroyed.

Vehicles over 25 years old are exempt from EPA and DOT requirements, although you will still need to obtain and prepare EPA and DOT paperwork to provide to a Customs and Border Protection (CBP) Officer in order to clear your vehicle through CBP.

If you bought or were given an imported vehicle from someone in the U.S., and they did not clear it through CBP before selling or giving it to you, there could be a problem. It is illegal to sell an imported vehicle that has not been formally entered, and it is subject to seizure.

What part of this don't you understand? Without the HS-7 and 3520-1 this vehicle is subject to seizure at any time. Until you get those documents filed properly it won't change. Ever.

Is your vehicle 25 years old? No

Do you have the HS-7? No

Do you have the 3520-1? No

Therefore the car isn't legal and will never be until you resolve this. Call the NHTSA. Call the EPA. I'm waiting for it.

Now go ship it to Canada and ship it back.

Edited April 17, 2015 by Matvei27

[Matvei27]

Because he evidently didn't want to do it I went and double checked myself.

Form SF-97 by itself does not in any way imply that a vehicle is legal for importation, sale, or operation in the United States or any US territory.

lmao

[slowridn73]

This is like doing donuts in a parking lot, lots of going around in circles but not going anywhere. Someone email this thread to NHTSA so we can move on.

[HarrisRacing]

Stop listening to Matvei.

He has never imported a car, nor does he know the rules and regulations of importation, nor can he help you out at the point you are in.

You know what, neither have I. I only know what CFR's I have read from my brief and limited reading on the history of my car. None of us know about the entire importation procedure. I would consult an attorney if I was having trouble.

DISCLAIMER FOR ALL POSTS HERE: THIS IS MY OPINION AND I AM NOT AN ATTORNEY DESPITE THE FACT THAT I CONSULTED ONE.

My car's history is near impossible to replicate. Neither he, nor I, know HOW it was actually imported and/or detained by the government. Lots of service folks got cars back into the states from Okinawa, etc and issued SF97's on them - this is likely one of those vehicles. The military humvee's you see around are similar. He may be correct about the fact that the SF97 doesn't clear the car for legal ROAD USE in the US, but it DOES legalize it from the importation issues as there are (as previously cited by myself) OTHER forms that would have been issued for EXPORT ONLY, or if it was a piece of FARM EQUIPMENT, MILITARY VEHICLES, etc (they wouldn't have used an SF97). The CFR (CODE OF FEDERAL REGULATIONS) I posted covers this where it deems that the car listed on SF97 can be sold into commerce for intended use on public roadways. He has no leg to stand on arguing against that it is CITED LAW. What he doesn't want to believe is that It also is the clearing from the CBP that basically registers this VIN with the CBP and I have shown the form clearly. So what, MY car doesn't have the "typical" importation forms he asked for...it is better...it has CBP clearing WITHOUT those forms and the article he posted about the FEAR of buying a car without forms...Is simply false. the article (and Matvei) keep pointing back to "any car ENTERING shall be" and it's simply not true as my car, somehow, entered and was released to the public FOR USE ON PUBLIC ROADWAYS AND INTO COMMERCE, by the government. Maybe it was a shady deal back then, maybe someone got "hooked up" but the CBP missed it AND CLEARED IT THROUGH CUSTOMS so their time has come and gone.

This draws the line on the jurisdiction of the CBP and I'll tell you why (but again this is MY OPINION AND I AM NOT AN ATTORNEY):

EVERYTHING Matvei is quoting about "any vehicle ENTERING the US..." Is strictly regarding IMPORTATION and clearance by the federal government into our borders. And he IS correct that even with those forms (or SF97) it doesn't magically make the car pass emissions and DOT requirements for the road ESPECIALLY IN YOUR SPECIFIC STATE...but we will get back to that. All the cases that he has "cited" - (LOL internet articles), have dealt with skirting the federal importation process and the people DIRECTLY involved with breaking the laws to do so. When the EPA, NHTSA suspect there was a smuggling issue they then sick the FBI to INVESTIGATE what happened. Once they find malice, they can confiscate the cars for all people involved who "entered cars into the US that didn't...". Sometimes they may find that people approached the importer to get something done illegally. And the government is reasonable and has to PROVE intent. That being said, this is why the end users of Motorex cars got their pass as they thought they were doing things right. I posted an ACTUAL JUDGEMENT from the EPA in such a case...I highly recommend you read it. He has posted internet articles that literally end with..."Faces up to....". No judgements. Nothing in writing that is any more true than stating "faces abduction by martians".

My car was already here and owned by the government. It was issued SF97 and was then CLEARED by CUSTOMS (Customs Border Protection) and has the CBP number on the SF97 (which honestly I may have never seen had I not been so attacked on this forum) that says "this car is in the United States and is in commerce for use on Public roads" and that's well and covered already. This step would have put my car where your car is...STATE REGISTRATION which unfortunately varies from state to state.

Now in the specific state they may ask for crazy things and NO IMPORTER can help you now other than try to get the documents the state is asking for. See the IMPORTER gets the car into the states and registered with the FEDs (this is where Matvei can't get past)...the rest is up to you. CARB approval, EPA issues, DOT requirements for state registration, etc. This is why in some states you don't need to wear a helmet on motorcycles and some you do. Why some states have emissions testing and others don't. Why some states the license plate stays with the car and others don't. I'm sorry you are in AZ...sounds like an effing PITA. Florida, on the other hand, is extremely lenient (from what I read). Louisiana is tough, but do-able I'm sure (never imported, don't know). I went so far as this conversation goes with my car to then provide MY specific state's requirements when receiving and issuing a title on SF97 (linked in previous post).

Now let's be hypothetical since I didn't even file the SF97 with the state of Louisiana (previous owner did). At that point they could have given him a title and then said "Yep you own the car, but sorry you can't register this car for road use because the state of Louisiana says....is required". Maybe they could ask for inspection, or police inspection, or whatever...but my state doesn't (and I posted their requirements). Previous owner got the title, I then consulted the DMV on what was required, they told me, I did it. Now I have an insured, registered for road use, Louisiana titled 1990 Skyline GT-R. Whether Matvei wants to believe that or not is his own personal problem. His SLANDEROUS accounts here are continuing the FEAR propaganda that importers (and big companies that want to stop black market importation) want you to believe.

MORAL OF THE STORY:

so, BEFORE YOU TALK TO AN IMPORTER, ALSO TALK TO YOUR DMV so you know you have everything you need. You see, smoking dope is legal in Colorado, but not here...and the separation of FED and STATE regulations is a huge issue in the states. The feds want their money and procedures and then EACH STATE wants their money and procedures. Good luck getting it all past both.

I hope that we can FINALLY agree that the procedure ISN'T one straight procedure and is dependent on LOTS of variables. Maybe mine is a loophole car? I don't care, I did it all legally to the letter of the law as required by my state and the federal government. Is my procedure replicatable??? I have no clue.

but again, he has yet to show us ONE SINGLE JUDGEMENT OR LAW from a person registering a car that he bought on any arbitrary state title (black market or not), that ended in seizure.

Edited April 18, 2015 by HarrisRacing

[HarrisRacing]

https://www.law.cornell.edu/cfr/text/41/102-34.305

Again, more Law as pertains to my car.

[Matvei27]

You are missing the point entirely mate. State legal does not mean federally legal. The DMV doesn't decide what cars are legal and what cars aren't.

Yes, your car is legally registered in Louisiana. I have no trouble believing this. That doesn't mean the car is *federally* legal.

The NHTSA and EPA requirements are federal. It doesn't matter what state you live in, the car has to be 21 years old to be EPA exempt and 25 years old to be NHTSA exempt. Your car was imported in 2007, when it wasn't even 21 years old, so you never were able to get the exemptions. Some states (California with CARB) have additional emissions requirements on top of the federal ones. For that, you are on your own. But you still need to meet the federal requirements, which you currently don't unless you reimport the car to receive the exemptions.

Instead of calling your DMV (who has nothing to do with the Feds) why don't you call the NHTSA hotline like I told you?

They will tell you the same thing I am telling you. I promise.

It's not just about importation and clearance. The car doesn't meet (or isn't exempt) from federal safety and emissions standards. You can get an exemption, but only by exporting and reimporting your car in December like I originally suggested.

I linked to those articles because since evidently you don't believe me I thought you should read other sources giving you the same information.

Apparently you won't listen to ANYONE, though. So I recommended you call the NHTSA, who will tell you everything I have just told you, but you refuse to do that as well.

The guy in Mississippi who imported a S15 Silvia in January of this very year is facing 20 years in jail and a $250,000 fine for EPA and FMVSS violations. The guy who bought the car had it seized.

As I told you before I don't think you are at risk of being charged with any crime since you aren't the original importer. Just like in the case of Kaizo, the owners of the company were the ones charged with the crime. But, even though the purchasers of the vehicles didn't do anything wrong, their cars were still seized because they did not comply with NHTSA/DOT and EPA regulations.*

It's the same situation you are in. You aren't at risk of being charged with a crime since you didn't do the original importing. But since your car isn't currently compliant with federal regulations, you *are* still at risk of having your car seized. I told you how to rectify that and get the exemptions you need, but you don't want to listen. All you need to do is ship it to Canada and back after Dec. 1st. File the HS-7 and 3520-1, tick box 1 on the HS-7 and code E on the 3520-1.

Note that the EPA goes by the calendar year of manufacture, but the NHTSA goes by the year+month.

Please, before you waste any more money on an engine build spend the $1000 to ship the car to Canada!

*Here is the very letter that was issued to the owners of Kaizo vehicles:

Edited April 19, 2015 by Matvei27

[HarrisRacing]

You gave it away first with the "called a USA state dept on friday night/sat morning". Then sealed the deal with the "mate". Where are you from really?

We are done here.

Edited April 19, 2015 by HarrisRacing

[Matvei27]

What do you mean? Do you want me to post a copy of my US passport here? Listen asshole, I was born in Los Angeles, live in the United States, and daily drive a R32 which I imported myself. Am I not allowed to use the word "mate" on an Australian forum because it is too cultured for your tastes there in Louisiana? You can't even f**king spell "your" right. I called them Friday during the day you dumb shit. I don't have to post the minute I call them.

Have you ever imported a car? No.

Have I? Yes, and I even drive one myself.

Do you have a business doing export/import? No.

Do I? Yes, I deal with CBP all the time. My customs broker is DCL at the port of Oakland, CA.

Your problem is that the only way to actually meet the EPA/NHTSA requirements is at the *time* of import. There is no process for doing so afterwords. Even if it is a vehicle that you plan on having conformed rather than one which is exempt, the vehicle has to go straight from the port to a bonded RI/ICI and cannot be released to the customer until the compliance work is complete and the work has been approved by the NHTSA and EPA.

Read the f**king letter I just posted from the DOJ! and call the NHTSA like I told you if you don't believe me. I already did, but you won't take my word for it.

I hope you spend tons on the engine rebuild and then have your car seized when you try and drive it on the road, all because you refuse to spend a grand or so to send it to Canada and back.

Edited April 19, 2015 by Matvei27

[HarrisRacing]

File ANY pertinent information and SOMEONE here will start to belive you. Shame on autocorrect.

A quick PICTURE or YOUTUBE video will vindicate you instantly. Get smart and think of a way to do it. Words on a forum and letters don't help.

[Matvei27]

I gave you so far:

Links to pertinent government regulations (EPA, NHTSA/DOT, CBP)

Links to articles from other parties (not me) backing up what I have been telling you from the beginning

Department of Treasury government auction rules

Links to news stories and examples of seized vehicles (including one from as recent as January of this year!)

A letter from the Department of Justice regarding vehicles which don't conform to NHTSA/EPA requirements

Please, read carefully what I said above and the letter. You are just ignoring the information that is already out there because it doesn't meet your confirmation-bias.

Edited April 19, 2015 by Matvei27

[HarrisRacing]

I'll mirror your questions.

Show us your import papers, tell us how you passed CARB, provide all information since you are LEGAL! This should be no problem for you. YOUR car, YOUR registration. What's the build date?

Quit dodging the issues. You haven't done it.

[Matvei27]

My car isn't in California so it doesn't need to meet CARB requirements.

I am not dodging anything, I filed a HS-7 and 3520-1 since my car is 25 years old. All you need to do is tick box 1 on the HS-7 and put in code E on the 3520-1.

I am not falling for your silly red herring, this is about your car not mine.

If you do want to register a "direct import" vehicle in California, it depends on the year it was made.

If it was made prior to 1968 it is exempt to California direct import requirements. If it is newer than 1968, but before 1975, it has to meet the an entirely different set of regulations from the current California smog program. This is not impossible, but it's difficult. CARB/BAR/CA DMV don't recommend trying to import cars within these years because of that. Newer than 1975 you need to do the federal test procedure, there are two labs in the state that can do it. They will run your car on the dyno and do a similar test to the ones that the manufacturers have to do when they certify a car for sale in California and the US. You won't have to meet everything, but you will have to replace things like the exhaust, catalytic converters, etc.

It will cost about $10,000 to do this. You will get a label from the BAR to stick in the door jamb certifying that you have done this compliance work. After that you can smog your car at regular smog stations. Unfortunately the two labs (one in Socal and one in Napa) are unable to test Diesel vehicles, so it is actually impossible to register direct import Diesel vehicles newer than 1975 in California.

If you need more information on registering a car in California and the federal test procedure, you can read about it here: (not my site, but the info here is accurate nonetheless)

http://www.importavehicle.info/2013/04/direct-import-vehicles-1975-or-newer.html

And here is the latest DMV bulletin regarding this issue:

http://www.dmv.ca.gov/portal/wcm/connect/95f31d40-b33e-4b9a-bb72-98cdab08ece9/14vin14.pdf?MOD=AJPERES&CONVERT_TO=url&CACHEID=95f31d40-b33e-4b9a-bb72-98cdab08ece9

You already by your own admission have a car which isn't 25 years old, and you already admitted you don't have a de-registration certificate, HS-7, or 3520-1.

What about this is so hard to understand for you?

Read this. If you don't do what I told you and try to drive this car around on the road you will be getting one similar to this.

These cars were even registered in CA with CA titles; doesn't matter to the Feds at all.

Edited April 19, 2015 by Matvei27

[Matvei27]

By the way, conforming a vehicle which isn't 25 years old (and therefore not exempt) can be extremely costly. I have been told about estimates from RIs as high as $960,000 to conform a R34 GT-R, not including the cost of the vehicle and shipping.

If a vehicle is already on the list of eligible vehicles, it can be significantly less. I know of one Audi RS4 Avant which was imported and conformed for around $50,000 minus the cost of the vehicle.

Currently the only Skylines on the eligible vehicles list are 1996-1998 R33 GT-R and GTS models. The problem is the only RI who could do the work (Motorex) as you know, went bust. Since then, no other RI has wanted to touch them.

Here is the current list of eligible vehicles:

https://docs.google.com/file/d/0B7BuxOyOE3T4bjB6YWJjSXJ2WkU/view?pli=1

And the current list of RI/ICI who can conform them:

List of RIs Who Conform Vehicles Manufactured for Sale in Countries Other Than Canada

Edited April 19, 2015 by Matvei27

[HarrisRacing]

Ok since you won't volunteer anything REAL, I'll take apart what you have volunteered.

A letter about an R33 written in California from the EPA in 2009. Easily found on the internet.

R33 model is 1993-1997. Letter written in 2009. Letter written from STATE OF California (literally the strictest state). 2009 (letter)-1993 (oldest R33) = 16. Not 21. This letter says "state of California doesn't like your R33 here" again proving my point that state supercedes feds....THANKS!

I'll wait for my letter from the state is Louisiana. Until then cry in jelousy and continue your slanderous name calling.

[Matvei27]

State doesn't supersede the feds. It's the other way around. If you notice that letter is sent by the Department of Justice, a federal agency. The address is from a federal court in California, not a local court. It has nothing to do with CARB or the CA DMV. I already explained to you that particular vehicle was legally registered in California. It had CA plates, a CA title, everything. The Feds don't care about any of that.

I already explained to you the difference between state legal and federally legal. Your car *IS* state legal. You legally registered it in Louisiana. The problem is it isn't FEDERALLY legal. So the feds can still seize your car. Understand? The DOT and EPA regulations are at a federal level. No matter which state you chose to register the car in, you have to meet these requirements. Some states have additional requirements on top of these federal ones, like California. But the federal requirements apply to ALL states and US territories.

As it stands right now, you are meeting the requirements of your state (which, in LA, is likely just paying the registration fees) but you are still in violation of federal law. So your state will not impound your car since you have a plate and your registration is current, but ICE (the Feds) will still seize it because it doesn't meet federal requirements.

state law and federal law are not the same thing! You can have a car which is federally legal but not state legal (i.e. a 25 year old car in California which has not been through the CARB testing procedures) and you can also have a car which is state legal (i.e. registered in Florida) but not federally legal. The latter is a much bigger problem because the NHTSA and EPA are federal agencies and their regulations apply nationwide including in US territories.

http://www.importavehicle.info/2011/11/is-my-imported-car-legal.html

Edited April 19, 2015 by Matvei27

[HarrisRacing]

Clearly the R33 in question was imported illegally, not released by the government for sale or use on public roadways, and the "obviously you know this" nature of the letter indicates that the owner knew this.

California sucks...I read that Arizona ain't far behind.

Again provide one single example of your personal experience.

Please provide law that pertains to my car's SF97 or shut the F+++ up about it!

You are not an importer

You are not a government official of importation or enforcement of vehicles driven on the road and no authority to tell anyone anything here

You have no direct experience with SF97 issuement, legalization, etc.

Your word is no more valid than Richard Simmons' word and you need to accept it.

Edited April 19, 2015 by HarrisRacing

[Matvei27]

You are just making shit up. I already told you I have more experience on this than you. I run an import/export business for arcade games, car parts, and cars from Japan. It is part time but a single container can be worth as much as 30,000 dollars. I have brought in 3 containers so far in 2015, not counting anything for myself (personal affects)

This has nothing to do with the states. I told you that R33 was legally registered in California. It had a CA title, plates, and insurance. This is all federal law. When it comes to motor vehicles aside from issuing additional requirements like the smog program in California there is very little the states actually do. All of the requirements are in the FMVSS which is maintained by the NHTSA and DOT in Washington DC.

SF-97 doesn't legalize a car. It is a temporary title used to transfer ownership when the government doesn't posses the original title. Even the link you posted says this:

§ 102-34.305 What forms do we use to transfer ownership when selling a motor vehicle?

Use the following forms to transfer ownership:

(a) SF 97, The United States Government Certificate to Obtain Title to a Motor Vehicle, if both of the following apply:

(1) The motor vehicle will be retitled by a State, Commonwealth, territory or possession of the United States or the District of Columbia; and

(2) The purchaser intends to operate the motor vehicle on highways.

Note to § 102-34.305(a)(2):

Do not use SF 97 if the Government-owned motor vehicle is either not designed or not legal for operation on highways. Examples are construction equipment, farm machinery, and certain military-design motor vehicles and motor vehicles that are damaged beyond repair in crashes and intended to be sold as salvage only. Instead, use an appropriate bill of sale or award document. Examples are Optional Form 16, Sales SlipSale of Government Personal Property, and SF 114C, Sale of Government Property-Bid and Award.

SF-97 should not have been issued like this because the car isn't legal for operation on highways as it doesn't meet EPA or NHTSA requirements and isn't exempt as it was not imported when it was 25 years old. It wasn't even 21 years old in 2007. That being said, it was issued either by mistake or with the intent of laundering the car. Either way doesn't matter since form SF-97 by itself doesn't satisfy the NHTSA or EPA.

Since apparently you will not listen to anyone and are more concerned with your turbo selection than sorting out your paperwork, I don't really care what happens to your car. But I will say that if you try to drive it on the roads or sell it it is going to get seized. It always catches up with people. It might take a few years, but without fail you will get a letter in your mail one day. Hopefully then you can think back on this thread and reflect on what I told you, even though it will be too late for the car

[66gt40lm]

The problem HarrisRacing seems to have is that state and federal legality are two different things...

But beyond that, and since this topic falls under multiple federal agencies, is that not all of them have to agree (and typically don't, just look at the twenty one year exemption for EPA vs. the twenty five year exemption for NHTSA). If ONE of those federal agencies disagrees with something, it's done. The NHTSA says it either has to conform or be over twenty five years old to be eligible for "exempt" status. This vehicle is neither. The GSA might say it's legal, but the NHTSA doesn't.

Government agencies don't work well together, contrary to what you might believe. That's the point I think Matvei is trying to make here. One agency saying it's legal doesn't mean it is *completely* legal.

Edited April 20, 2015 by 66gt40lm