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Interpretation Response #16-0038

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 03-08-2016
Company Name: Lear Corporation-Guilford Mills    Individual Name: Ms. Laura Jones
Location state: MI    Country: US

View the Interpretation Document

Response text:

March 8, 2016

Ms. Laura Jones
Manager – Customs
Lear Corporation – Guilford Mills
21557 Telegraph Road
Southfield, MI 48071

Ref. No. 16-0038

Dear Ms. Jones:

This responds to your March 4, 2016 email concerning exceptions accorded to safety devices that are installed in completed vehicle components under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Your company imports completed seat frames from Mexico with approved safety devices (i.e., air bags) attached.  Upon importation, the seat frames are shipped to your company’s plant in Arlington, Texas for assembly into seats.  In your email, you inquire whether a completed seat frame assembly containing an approved air bag module is excepted from the requirements of the HMR under 49 CFR 173.166(d)(1).  

The answer is yes.  As prescribed in 49 CFR 173.166(d)(1), a safety device that is classed as a Class 9 (UN3268) under the terms and conditions specified in 49 CFR 173.166(b)(1), and is installed in a motor vehicle, aircraft, boat or other transport conveyance or its completed components, such as steering columns, door panels, or seat assemblies, is not subject to the requirements of the HMR.  Further, the conditional exception from further regulation for completed components containing approved safety devices is recognized globally.

I hope this information is helpful.  If you have any more questions, please do not hesitate to contact this office.


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

173.166(d)(1), 173.166(b)(1)

Regulation Sections

Section Subject
§ 173.166 Safety devices