I have been hearing about a certain large importer of mini trucks based in Oklahoma that is having a terrible time getting his trucks released by Customs in Dallas due to insufficient thickness of the metal plates that are being used to make the "EPA Approved" speed limiters. Customs has actually seized his container per instructions by EPA and they are giving him the choice of either re-exporting the container (7 trucks), or having the trucks destroyed. Can anyone provide a link to this regulation or quote the EPA section number? This might be something to watch. Everyone should watch their P's and Q's when suggesting these trucks are "legal" to drive in some states. I agree with some of the more conservative (maybe even protective?) dealers that are saying that these trucks should not be allowed on the highways. As a Customs Broker myself, I can tell you that they are classified as works trucks - not for highway use. And just because you might be able to bypass the motor vehicle requirements at a state level does not mean you have met the requirements at a federal level. In other words, you might be OK with your state DMV, but you are definitely not OK with Customs (CBP) or EPA. If you are a wholesaler/dealer, make sure these trucks have the right type of limiter and do not remove (don't even suggest removal) the limiters prior to the final sale.
http://www.fmcsa.dot.gov/rules-regulations/administration/fmcsr/571.500.htm ยง571.500 Standard No. 500; Low-speed Vehicles http://www.nhtsa.dot.gov/cars/rules/import/FMVSS/index.html FEDERAL MOTOR VEHICLE SAFETY STANDARDS AND REGULATIONS http://www.epa.gov/otaq/imports/factmnb.htm http://www.epa.gov/otaq/imports/quikover.htm
We know the large importer in Oklahoma. That is very true! We spoke with him last week. The metal plate used to build the speed limiter boxes installed on his trucks were slightly under sized. He has been fighting with customs for weeks! We are hoping it all works out for him. Make sure your suppliers are installing atleast .080 thickness.
Thanks, but I already have the EPA links and DOT links. What I am looking for is the specs on an "EPA approved speed limiter". Are you telling me that EPA has published its requirements on the thickness of the limiters? Is this somewhere in the links you have sent me?
regs I didn't read the links, however, I remember from the letter we recieved from the EPA when this all came down last summer that it was spec'd at 1/8" thick. Also, the overall designs have to be registered with EPA. For the record, all trucks both on our lot and leaving our lot are speed limited. Our customers sign off that this is the case on the BOS and purchase agreement.
