US Deponment

\61\6e US Deponment o Transportnint National Highway Traffic Safety Aarehesitation Subject: From To: DV' T. r.7 pron TATi CH memorandum 02 25 Ali 9:59 na,y-r-2, A in- • -3) to Petition for Import Eligibility Date' JUN 4 axe Decision on 1999-2002 Mercedes Benz S Class (W220) Paygegger Ca Reply to Mn. Attorney Docket Management Please place the attached petition for a decision that nonconforming 1999-2002 Mercedes Benz SL Class (W220) passenger cars are eligible for importation in Docket No, NHTSA-2002-12316. Attachment perk SAFETY BELTS SAVE LIVES EFTA_R1_00015472 EFTA01734989 AMC automobile concepts Inc, 13329 ne 17 ave n. Inform, 11 33181 tel 305 893-1950 tax 305 89:1-9097 Registered Importer 01-278 PETITION FOR IMPORT ELIGIBILITY DETERMINATION To: Administrator National Highway Traffic Safety Administration Room 6111 400 7th Street SW Wom;ngton, DC, 20590 Attn NEF-32 Import Eligibility 3-6-2002 Dear Mr. Loy: The following is the basis for this petition: Pact 593,6fal The vehicle for which a determination is sought is a 1999-2002 Mercedes Ben Saws Mr2201. VIM WDB2200701A065048. We have examined the recall campaign and we have found that there are 2 pending: 1. Campaign ED 00V 141000 Component: air conditioner electronic climate control module. 2. Campaign 13D 01V014000 Component: visual systems windshield washer. These existing and future Campaigns will be corrected and all necessary parts exchanged. Pert 5934 lel 121 The vehicle which is substantially similar to the petition vehicle is the US version. Part 593.6 [al 131 The vehicle which we believe to be substantially similar is manufactured Dr See in the USA and it was certified to meet all applicable Fb4VSS in effect at the time of manufacture. The non-conforming model was not listed on dr.: accepted DOT list in SS PR 219, pp 212, 47418ft or the updates that have been publisbedji previous petition was approved for tb e 2000- 2001 Mercedes Bone S 500 41 S 600 fVSP 3711.1 ightences between the US model and the non-certified model are way minor and have been outlined in this petition. EFTA R1_00015473 EFTA01734990 (' CFR 565 A "Vehicle identification Plate" must be added near the left windshield post and a reference And certification label must be added in the left front door poet area to meet this FMVSS. Copies of all labels will be included in the final report ?MUSS 116 The vehicle came equipped with DOT brake fluid and the top of the master cylinder with the DOT information jMVSS 118 The power window system has to be reprogrammed so that the windows will not operate with the ignition off. FMVSS 124 The ameleration 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. / FMVSS 20i The components subject to this FMVSS are identical to those in the US omorranitm mucH. This model has been identified as meeting the upper interior brad impact requirements by the manufacture. Each vehicle must be inspected to confirm that the appropriate parts are in place and any parts found to not bare the US parts must be replaced with US components. [kis rM1f ,14 Ccc cif 44t p nriCcf /tn. l• 445' t- v/ pmvss 202 This vehicle came equipped with head restraints that are identical to those on the US motel. FMVSS 203 N/A when FMVSS 208 it; met. Conforms to S5.1 of FMVSS 208, Impact for steering controls systems. FMVSS 204 The steering shaft on this vehicle are energy absorbing and is identical to that on the US node'. EFTA R1 00015474 EFTA01734991 IMVSS 205 The glass and glazing material used on this vehicle are identical to those used on the US model. They are clearly labeled with DOT AS-1 or DOT AS-2. DIVSS 204 The door locks and retention components are identical to the US model. 7MVSS 207 ____IrThe gearing svcttm — — •"ani nglarmirl ' FMVSS icu r cu), 'angel due to lent S *1/4:frao "stin tits) those of stet Um ItandardS. This vehicle is equipped with a seat belt warning lamp that is identical to that used on U Model. However, the warning buzzer must be reprogrammed. The passive restraint system used in these vehicles consist of dual front airbags and knee Banana. They also have combination lap end shoulder bolts at the out board front seating positions as well as at the rear outboard seating positions. These manual systems are ant matie self tensioning and are released by mean of a single red pusb-button. All vehicles =tains the USA must be inspected to confirm that the systems bear the US part * on the etthetts rpert # AC no OCA in net WA•n•Inu I j Sensors and seatbelts. Some parts coming from Europe countries may need to be c varying regulations. However, Gulf states cars have US systems as standard equip, VSS 209 l'k-Seatbeit labels arc identical to thoseion the US model and they meet this FMV (IM'VS7CTIWieatbelt anchorages are identical to those on the US model. FMVSS 21Z + Mt? The windshield intrusion zone and the parts are engineering thereof are identical tc The US model 7-(9--IMVSS 214) / Doorbars in this vehicle are identical to those in the USA model. All vehicles that Country must be inspected for compliance with this regulation due to varying Euro EFTA_R1_00015475 EFTA01734992 49 CFR 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, arc 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 require mans. These evaporative systems have a rollover and check valve incorporated in their design. invitin: 5Ptkic 1'144 P.i2A _ Co0t1%,-4;:.S. ITr , • : i.• EFTA_R1_00015478 EFTA01734993