I didn't want to post this in the Off Topic department since Seņior Info probably only hangs out in here. (so please do not move).

Anyway Senior - You seem to know the rules pretty well. Is it possible to have a Lotus Elise (or exige) shipped in to the country without engine, then put a Honda engine in, and have it be a legal "kit car"? It seems like it should be ok, but the gov't is pretty tricky sometimes.

Thanks

ps....for those who want to make a ņ, hold down the Alt key and type "0241" ņ Capital is Ņ "0209"

 

Here is how I would import a new high performance car from overseas (e.g. a Lancer EVO from Japan or the UK) as a "kit car" not subject to NHTSA's FMVSS (Federal Motor Vehicle Safety Standards), Bumper Standard or the Theft Prevention Standard.

I first would rely on NHTSA's interpretation letter issued in 1999 to a guy in England who wanted to ship kit cars to the US. So, in order to be considered merely a motor vehicle parts manufacturer and NOT a motor vehicle manufacturer, my company would, after purchasing the new car in Japan or the UK and before shipping it to the US, have the powertrain removed, the body separated from the chassis, and the bits (like headlights, reflectors, etc.) that don't meet DOT parts standards removed. I would ship chassis and body in separate containers and truthfully declare each on the Customs Declaration as Motor Vehicle Parts (2.5% duty) and on NHTSA's HS-7 Declaration form, I would truthfully check Box 2.

After my "parts" had arrived in the US, I would then rely on NHTSA's interpretation letter, again issued in 1999, to a guy in California that wanted to supply kit cars without a powertrain. I would mate the body and chassis together and replace with, DOT-approved parts, those bits (headlights, relectors, etc.) I had to remove overseas.

So now my "kit car" is available for sale, completely assembled except that it lacks a powertrain. Getting an automobile powertrain through Customs normally involves an EPA declaration. I won't address this part of the equation except to observe that it seems people manage to import many non-EPA-compliant JDM automotive powertrains, perhaps falsely declared as "fixed power generators" or "aircraft engines." I can't help you get a powertrain. I just supply the kit.

Almost forgot. I would also include a notice with each "kit car" that I sold to the effect that anyone who installs a powertrain in it shall be responsible for insuring that the resulting motor vehicle complies with all applicable FMVSS.

I would also like to point out that Sun International used to be an RI but is not one now. It doesn't take much money to maintain your RI status once you get it, so I'm guessing that NHTSA yanked Sun's RI certification, perhaps because they crossed the line in one of these "gray" areas related to NHTSA rule interpretation.

 

Thank you for the informative post. That is way too much work for me... I would be better off stripping down my S2000 than to spend $50k++++ and 9 months attempting that, but i would still be done before a legal EVO VII hits the roads

 

Non-chassis mounted engines do not require an EPA cert. I read up on this when a friend of mine had his new Talon engine on hold when it came in from the builder in Canada. We ended up having to "educate" customs on this little change in order to get his engine released in our lifetimes These engines are technically illegal for road use, but it's obviously not enforced given the number of SR20 Nissans and Hondas with JDM engines in them. Getting them through customs is easy.

The other problem with kit cars is that some places have a "50% rule". The car cannot consist of more than 50% of parts from a single manufacturer. A Lancer would probably be at least 80% Mitsubishi. If you were REALLY daring, you could probably come up with a supplier list (real or imagined )for every nut, bolt and spring on the car and maybe squeeze it under the percentage, but that would be tedious in the extreme.

I'd also like to know how they're importing Lotuses WITH the original motors up here in Michigan. There has to be a scam somewhere. I've seen a couple of Elises with the stock engine and I've talked to the dealer who sells them. He didn't tell me much other than it would cost me $50,000 to own one.

You can see their website here: http://www.auto-euro.com/

I have some closeup pics of the cars if anyone is interested.

 

Here's some good news. There is a "common business practice" among Japanese automakers (as well as in many other manufacturing businesses) that is referred to as "keiretsu". A Keiretsu gaisha is a company that cooperates in the production of a particular product through the exclusive manufacture of one or several components. Keiretsu compose what appears to the outsider (read:gaijin) to be a loosely organized group of partner corporations, when, in reality, interaction between the principals is maintained via deeply obligatory and hierarchical relationships.

In the Keiretsu system, a very small shop in Nagoya, with perhaps ten employees, may cast one specific screw or washer that will be installed on every single Toyota Corolla produced worldwide. Aluminum alloy must be composed of no more than 15% recyclables for certain products, but if you ever wonder where 125 million people put their aluminum soft drink (or milk tea) cans, look no further. The units required to fill weekly orders can be mind boggling.

Another mom and pop business in Kyoto with 25 or 30 Bolivian master tool and die makers may use $25 million dollars worth of robots arms and calibrated Numerical Control machines to mill and polish the screws. Military standards of QA inspection (100% AQL) are usually deployed, and total recalls of substandard lot #s (4% variation) are not uncommon.

Each automobile component may be composed of several of sub-components, all of which were manufactured at different facilities by different corporations.

The specifications are sent to these keiretsu via analog data transfer to National/Panasonic terminals. These terminals run an antiquated operating system similar to DOS, which is exclusively used for the automotive industry. Most parts are assembled by major suppliers to the Auto manufacturer, some of whom are even located in Bavaria and Italy.

Bosch, for example, imports Japan-made cylinders to manufacture brake components that are shipped back to Japan for assembly into certain Honda and Nissan models. Since these components already meet the Ministry of Energy, Trade and Industry's Standards and Measures regulations, they can be imported back to Japan by Japanese Manufacturers with a minimum of red tape and arrive Just-On-Time in most cases.

Japan and Germany have a special, longstanding trade relationship. Since 1997 (and perhaps even as early as 1943), Japanese auto manufacturers, like Toyota, began to cast and mill specific engine parts (regulator casings) in Shenzhen City of Guangdong Province (Mainland China). Guangdong, or Canton, is a Special Trade Region. The parts are shipped back to Japan, and, once again, assembled by third party contractors into components and sent to assemby facilities Aichi Prefecture.

What this all boils down to is that NO Lancer manufactured in Japan by Mistubishi contains 80% Mitsubishi parts. Mitsubishi could never afford to maintain so many QA staff, even if they could achieve 100% assembly automation. The success of Japanese Trading Companies, who arrange for the paperwork, certification and logistics in the transfer of goods from one facility to another, was based on Keiretsu. The high cost of personnel, shipping, and insurance has beat them down to their knees. As a result, the Japanese practice of "lifelong employment" with a single conglomerate is no more. An American with minimal command of the Japanese language, few contacts in Japan, and some common ingenuity could easily obtain a list of keiretsu gaisha utilized in the production of Mitsubishi's Lancer Evolution model.

How do I know all this? I've worked as a consultant for METI, when they were the Ministry of International Trade and Industry, at the Japan Patent Office, and for an ABS brake component manufacturer of about 150 employees with their own molding and milling units: [URL=http://yoshidanet.co.jp)Yoshida Kogyo Kabushiki Gaisha[/URL]. I also worked at the Tokyo Head Offices of the 11th and 4th largest trading companies in the world, Kanematsu Group, and Marubeni Sogo Shosha, respectively.

Thus, another HUGE but seemingly inconsequential loophole presents itself. Keiretsu is a practice that very few Americans know about, unless they've tried to break into the Japanese Automobile Manufacturing Industry, or represent and American Auto Manufacturer trying to develop markets on Japanese soil. WTO rulings and sanctions have little or no effect on Japanese business practices that have been an integral influence on scoiety and culture since the Internationalization Boom of the mid-1970's. Japanese Automobile Industry Senior Executives do more business on the golf course, than in any board room, and potential US Evo/Skyline GT-R importers should be aware of it.

 

That was really informative. Thanks.

I'd have to do some research on this some more, but the more I think about it, the more I think the "supplier" catch wouldn't work. The bits and pieces may be made by outsiders, but they're still SOLD by Mitsubishi or Lotus or whoever.

But what do I know? I'm just a hopeless dreamer