Have Trouble to import TPP Pass Side Mirror into European Union - please help me out

Discussion in 'Repro Parts' started by weinh, Dec 10, 2019.

  1. weinh

    weinh Well-Known Member

    Hey guys,
    I hope you can help me sorting out the mess I have here.

    Ordered one of these tri shield passenger side mirrors from Todd (DC musclecars). The joy lasted only until I got ordered to the local custom authority, where I had to learn that they could not release the mirror for use in the European Union.
    They are arguing that in the EU the outside mirrors for vehicles need to have a marking to illustrate that they comply to existing laws. As this is an US based reproduction mirror, they are aiming for some kind of SAE or DOT mark, which the mirror does not have.

    After some heated discussion with them it seems the only way to solve this issue is to provide them with some proof or reference document, that this reproduction mirror, in order to use it in the US, does not need to have any marking.
    So this is what I am looking for. Do you have an idea what kind of document this could be?

    I learned that there is a FMVSS no. 111, which deals with requirements for rear view mirrors, but I was not able to find out whether or not that would be applicable to the repro Mirror from TPP. It seems to adress rather modern equipment.

    Any support is highly welcome...

    Thanks Carsten
  2. flynbuick

    flynbuick Guest

    I do not have a NOS passenger side mirror handy but I not recall those marks on the factory mirrors. They are listed in the Buick parts books as an accessory. See if a member can take pictures of a NOS one along side the factory box.
  3. pbr400

    pbr400 68GS400

    What if you tell them it’s not going on a roadgoing car, but rather a static museum display? (Or it’s a tractor accessory or novelty item or ?)

  4. Mike B in SC

    Mike B in SC Well-Known Member

    Looks like a make-up mirror for your wife to me... :^)
    pbr400 likes this.
  5. weinh

    weinh Well-Known Member

    Jim, if I understand those people correct, I would not have any issue if it where a NOS mirror. It is because it is a actual reproduction which has to comply to actual laws, so they say (don't ask me where the sense in that is, I just try to repeat what they told me).
    But yes, it could be of help if somebody has pictures of NOS hardware which show there is no marking.

    Patrick, I tend to say it is too late for any kind of alternative story... Be sure I learned something for the next occasion though.
  6. Cutlass

    Cutlass Platinum Level Contributor

    Oh Boy, Carsten, I feel for you. Claiming, that this is for a historic vehicle did not help? I Keep my fingers crossed that it will work out for you!
  7. priariecanary

    priariecanary Stacey

    The Federal Vehicle Motor Safety Standards (FMVSS) are revised and updated every few years. It sound like you would need to show them what FMVSS 111 required for markings back in 1970. FMVSS standards are available online but I am not sure how to find older versions. Let me do some checking to see what I can figure out.
  8. PatricksBuick

    PatricksBuick PatrickBuick

    I feel with you..... from own experience.
    did they make notes of your conversation? Or could it be next time you go there and a different Beamter is going to do declaration has a different view?

    I agree that the support of some original documentation/pictures (part numbers?) might help proving that this part belongs to a veeeeeeeerrry old car. This might make it clearer for them that the whole GM vehicle was approved as is/as produced, but not every single part was stamped by GM/US authorities to be compliant with German regulations. Hence this mirror being a 1:1 (OEM) replacement of an old car which was once upon a time approved for German road use (no custom part.. blabla crap) does not have and does not have to have such a marking.

    Good luck!!!!

  9. weinh

    weinh Well-Known Member

    Stacey, an issue of the FMVSS 111 out of 1970 would be of great help, many thanks.
    Maybe the 111 did not even exist back then (that would be the best scenario)? The very first FMVSS document (no 209) has been released as late as 1967...

    Ralf and Patrick, thanks. I have to admit, when I discussed with the customs guys I underrated the issue at first. The customs authority by itself is not allowed to make a final decision, so they submitted a formal request to the Kraftfahrzeugbundesamt (federal vehicle authority). If those guys in turn received all infos on hand, like the car being a 50 years old classic, I do not know. I only know that their judgement came out negative.
    I now try to convince the authority behind the authority that they have made a wrong statement. Feel like Don Quixotte fighting against windmills, maybe you now that character...
  10. priariecanary

    priariecanary Stacey

    I tried find a copy of FMVSS from that time period online and no luck. Back then the federal regulations were published in books and I would have had to have found a searchable scan of the book from back then. FMVSS 111 first became effective as of January 1, 1968 so I would have to find copy of the book from 1967 or earlier.

    I am not sure if it will work but you can remind the customs guys that the US has a different regulatory structure than Europe. In just about Europe everything has to have an e-mark indicating that some independent authority like TUV verified the compliance of the item with the relevant regulations. In the US, companies self-certify and most objects don't have any compliance markings. The companies just need to demonstrate compliance if NHTA asks, and the real motivation for compliance is to avoid a lawsuit from some product liability lawyer.

    Sorry I couldn't be of more help...
  11. Houmark

    Houmark Well-Known Member

    Have them to send it to me, then I'll send it to you again.. When it comes from Denmark, which is a part of the EU, the mirror will pass right through..

    Our rules are ridicules as well, but have never heard a problem like that with classic parts, nor anything else..

    I live in Denmark..
  12. weinh

    weinh Well-Known Member

    Stacey, many thanks nevertheless. The earliest revision I was able to find dates back to August 26 1976 (41 Federal Register Page 36025). Will continue to look for the 1968 one.

    Søren, many thanks for your offer. Unless I could convince the KBA that their first assessment is utterly bullshit, my choices are limited to aa) send it back to the vendor or bb) have it destroyed.
    Houmark likes this.
  13. pbr400

    pbr400 68GS400

    Good luck in your quest to change their minds. If that fails, send it back and have your neighbor order a ‘make up mirror’!
  14. weinh

    weinh Well-Known Member

    That is the fall back solution, no doubt... :)
  15. Cutlass

    Cutlass Platinum Level Contributor

    Hi Carsten, any (hopefully good) news in regards to this matter?
  16. weinh

    weinh Well-Known Member

    No news yet, government agencies are in their Xmas break.
    I filed an opposition against their decision and supplied some (hopefully) good arguments. Knock on wood...
  17. BrunoD

    BrunoD Looking for Fast Eddie

    If it all fails,send the mirror back to Todd,have him ship it to Soren in Denmark and he will send it to you.A little costly,but you will get it.Bruno.

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