EFTA01119026.pdf

DE”LCFI &VrORTATICH MeMOrandUM 61\6 \b e USDepornreg ie. ciTranspoc ticffional lighway 02 At 25 MI 9:59 Traffic Safety Administration Adri2)A-0- Subject: Petition for Import Eligibility oat. JUN 4 2:1Q Decision on 1999-2002 Mercedes Benz S Class (W220) Pa e ger Ca Reply to Flom: Ann. Attorney To: Docket Management Please place the attached petition for a decision that nonconforming 1999-2002 Mercedes Benz SL clAse (W220) passenger cars are eligible for importation in Docket s p. NHTSA-2002-12316. Attachment OSP SAFETY BELTS SAVE LIVES EFTA01119026  arc automobile concepts Inc,13373 ne 17 ass it. intend, it 33181 to 306 893-1960 fax 306 8934097 Registered Importer 01-278 PETITION FOR IMPORT ELIGIBILITY DETERMINATION To: Administrator National Highway Traffic Safety Administration Room 6111 400 74 Street SW Washington, DC, 20590 Attn NEF-32 Import Eligibility 3-6-2002 Dear Mr. Loy: Thefollowing is the basis for this petition: Part 593,6181 [11 The vehicle for which a determination is sought is a 1999-2002 Mercedes Berm S-Clan :VV2201. VIN# WDB2200701A065048. We have examined the recall campaign and we have found that there are 2 pending: 1. Campaign ID 00V 141000 Component: air conditioner electronic climate control [node.]e. 2. Campaign ID 01V014000 Component: visual systems windshield washer. These existing and future Campaigns will be corrected and all necessary parts exchanged. Part 593.6 (al 121 The vehicle which is substantially similar to the petition vehicle is the US version. fart 593.6 [al (31 The vehicle which we believe to be substantially similar is manufactured for Sale in the USA and it was certified to meet all applicable FMVSS in effect at the time of manufacture. The non-conforming model was not listed on the accepted DOT list in 55 FR 219, pp 218, 4741811; or the updates that have been published, A previous petition was avoroved for th e 2000- ,2001 Muccdcs Benz S 500 S 600 IVSP 371]. The differences between the US model and the non-certified model art very minor and have been outlined in this petition. EFTA01119027 fart 5916 fal 141, Since a USA companion model exists, we seek your determination that our petition velticle Is substantially similar to the USA model and therefore in eligible for importation and modification in the `substantially similar" category. We have examined the printed text from list The dealers both in the USA and in Europe and we have compared the computerized pats From Europe and the USA to determine both what difference exist and what parts will be necessary to bring our non-conforming model into conformance with all applicable FWVSS in effect at the time of manufacture. These differences and changes have been outlined in the Following examination of each applicable FMVSS. Part 593.6 fal [S] The following outline will show that our non-conforming vehicle was originally manufactured To conform to the FMVSS in many areas in the same manner as its US companion mole. MAW of the concerned parts have the same parts numbers as the USA models. I all areas that have to be modified the parts will be supplied by the manufacturer. The modifications to this vehi :le do not concern the basic structure, only easily removable and available pans. FIVIV,S$ 101 Rxcept as shown below, all controls and displays meet this FMVSS in the saute manne: as the USA model. The word "Brake" must be added to the dash in place of the international ECE warning symbol [Part # 220 584 04 17] The speedometer has to be reprogrammed and the face must shows MPH, or the Entire instrument cluster on these vehicles must be changed to the US part. [Part H 220 540 15 11 or 220 540 52 11] FMVSS 102 The markings starter interlock, shifting pattern, and brake effect are identical to those it the US model. FMVSS 103 The windshield defogging and defrosting systems are identical to those in the US mode l FMVSS 104 The windshield wiping and washing systems are identical to those in the US modeL EFTA01119028 FMVSS 105 The hydraulic brake system and the parking brake system are identical to those in the U:3 model. FMVSS 106 The brake hoses arc identical to those in the US model. The following modifications must be made to fully meet The FMVSS: a. Install US model headlamps. [Part ft 220 820 12 61 and 220 820 11 81] b. Install US model side market.. [Parts 220 820 01 21 and 220 820 02 21] c. Install US model tail lamp assemblies which incorporate rear side marker lights Wart $ 220 820 06 64 and 220 820 05 64] d. Install US model high-mounted atop light assembly [if necessary] FMVSS 109 This vehicle came equipped with tires that bear the "DOT' symbol A tire placard must be installed to meet this FMVSS requirement. Fl11N/SS 111 ) The driver's inside and outside rearview mirrors meet the FMVSS. However the passenger's Rearview outside mirror must be changed to the US companion model part to meet the Requirement or etched with the appropriate statement [Part it 220 810 12 21] FMVSS 113 The hood latch system is identical to the one used on the US model. FMVSS 114 The vehicle must have the wanting buzzer activated to meet this FMVSS jcpb6 4 ) 5(-)2 EFTA01119029  CR 565 OA "Vehicle identification Plate" must be added near the left windshield post and a reference And certification label mutt be added in the left front door putt area to meet this FMVSS. Copies of all labels will be included in the final report. The vehicle came equipped with DUI brake fluid and the top of the master cylinder with the DOT information IMVSS 118 The power window system has to be reprogrammed so that the windows will not operate with the ignition oft FMVSS 124 The at control system is identical to the US model. FMVSS 135 (105] The hydraulic brake system and the parking brake system are identical to those in the US model. rymvss The components subject to this FMVSS are identical to those in the US companionmod/1 This model has been identified as meeting the upper interior head impact requirements by the manufacture. Each vehicle must be inspected to confirm that tho appropriate parts are in place and any parts found to not bare the US parts must be replaced with US components. FMVSS 202 -rik74 recets ^14 ecc+,4--phafgn ityMe_t 4,-/naca26-49 EMV203SS This vehicle came equipped with head restraints that arc identical to those on the US model. N/A whet FMVSS 208 is inct. Conforms to 55.1 of FMVSS 208, Impart for steering controls systems. FMVSS 204 The steering shaft on this vehicle arc energy absorbing and is identical to that on the US nodel. EFTA01119030  DAM 205 The glass and glazing material used on this vehicle aro identical to those used on the US model. They are clearly labeled with DOT AS-I or DOT AS-2. MINIS 206 The door locks and retention components are identical to the US model. jrMIVSS 207 The system in this vehicle is identical to that used on the US model. FMVSS 308 This vehicle is equipped with a seat belt warning lamp that is identical to that used on US Model. However, the warning buzzer must be reprogrammed. The passive restraint system used in these vehicles consist of dual front airbags and knee Bolsters. They also have combination lap and shoulder bolts at the out board front seating positions as well as at the rear outboard seating positions. These manual systems arc automatic, self tensioning and are released by mean of a single red push-button. All vehicles entering the USA must be inspected to confirm that the systems bear the US pan # On the airbags [Part # 220 460 06 98 and 220 860 10 05], control unit [Part # 220 820 44 26], Sensors and seatbelts. Some parts coming from Europe countries may need to be changed due to varying regulations. However, Gulf states cars have US systems as standard equipment seatbelt labels are identical to tboseion the US model and they meet this FMVSS zreir ner ( el.-Abell anchorages are identical to those on the US model. (,/ilit on Cat 5 -coo *i_j_fivi th yeti'kg ia FMVSS 21Z 7n/CS) The windshield intrusion zone and the parts are engineering thereof are identical to those of The US model r- FMVSS 214 Doorbars in this vehicle are identical to those in the USA model. All vehicles that enter the County must be inspected for compliance with this regulation due to varying Euro standads. EFTA01119031 42CFR Part 581 The bumpers and the support structure for the bumpers on these vehicles are identical to the US model. FMVSS 218 The windshield intrusion and the parts or components thereof, are identical to those of the US model. FMVSS 301 The fuel system in this vehicle is identical to that of the US model. Fuel spillage problerr s are controlled by the evaporative system that was installed by the factory for the EPA requirt malts. These evaporative systems have a rollover and check valve incorporated in their design. sficlay flist &ix coeTwk$ 1.27,1410(42.5 FMVSS 302 This vehicle is equipped with interior materials that are identical to those used on the US model. Thank yvu or 2 ur attention Ramez Wahab Automobile Concepts, Inc. EFTA01119032