REGISTERED IMPORTER NEWSLETTER No. 29
National Highway Traffic Safety Administration
Office of Vehicle Safety Compliance
June 2, 2006

Revisions to Suggested Statement of Conformity Form

A Registered Importer (RI) must submit to NHTSA, upon the completion of conformance modifications to each nonconforming vehicle the RI imports, certification that it has brought the vehicle into conformity with all applicable Federal motor vehicle safety and bumper standards.  The certification must be submitted within 120 days from the date of importation and must be supported with documentary and photographic evidence of the vehicle’s conformity.  The documents that are submitted on each vehicle are commonly referred to as a “conformity package.”  Normally, the conformity package will include a form, signed by the RI or by the RI’s designated representative, that includes identifying information on the vehicle, statements certifying that the vehicle has been brought into conformity and that certain other requirements have been met, and a list of Federal motor vehicle safety standards (FMVSS) and other applicable requirements with check-off boxes that permit the RI to identify whether the vehicle complies with the standard or other requirement as originally manufactured or as modified, or whether the standard or other requirement is not applicable to the vehicle. 
NHTSA has previously made available to RIs a suggested form for submitting the Statement of Conformity.  NHTSA has periodically updated the suggested form as new standards are adopted or pertinent regulations are amended.  The suggested Statement of Conformity form was last revised in October 2001.  While RIs are not obligated to use the suggested Statement of Conformity form, they can rest assured that all necessary certification statements will be made if they properly complete the form.

We have revised the suggested Statement of Conformity form to include additional information that must be submitted with the conformity package under amendments to the regulations governing the activities of RIs that became effective on September 30, 2004.  A copy of the revised Statement of Conformity form (dated June 2006) is included with this newsletter.  A copy will also be posted on the NHTSA web site at www.nhtsa.dot.gov/cars/rules/import.  RIs may download this form for their own use.

The form is divided into three sections that are arranged in a vertical order.  The top section includes identifying information on the RI and the subject vehicle, as well as information pertaining to the vehicle’s importation.  The middle section contains the list of FMVSS and other applicable requirements, and includes check-off boxes for the RI to use in identifying the vehicle’s conformity status.  The bottom section contains certification statements and a signature block.  Specific changes that have been made to the suggested Statement of Conformity form are described below:

Five new blocks were added to the top section.  These identify: 1) the address where vehicle was conformed; 2) the address where vehicle can be inspected; 3) the service insurance policy number; 4) the insurer’s name; and 5) a check-off block to indicate whether the RI’s certification is the initial certification for the make, model, and model year of the subject vehicle.

Three new FMVSS were added to the middle section.  These include: 1) FMVSS No. 129, New Pneumatic Tires for Passenger Cars; 2) FMVSS No. 404, Platform Lift Installations; and 3) FMVSS No. 500, Low Speed Vehicles.  In addition, the statement regarding conformance to the Theft Prevention Standard in 49 CFR Part 541 was moved from the middle to the bottom section.

Three certification statements are found in the bottom section of the revised form.  Each of these statements includes alternative responses, only one of which may be selected by checking the appropriate box.  The first statement identifies either that the vehicle is not subject to any safety recalls, or if it is subject, whether the defects or noncompliances that prompted those recalls have been remedied.  The second statement identifies either that the vehicle is not subject to the parts marking requirements of the Theft Prevention Standard, or if it is subject, whether the vehicle complies with those requirements as manufactured or as modified prior to importation.  The third statement contains the RI’s certification that the vehicle complies with all applicable standards.  We have also added a block for the printed name of the RI or its designated representative.  The RI or its designated representative must also sign the form with an original signature, and not with a machine stamp or other facsimile.