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Since I was told I'd need a MSO (Manufacturer's Statement
of Origin) for my frame to register my locost in Hawaii,
I've been looking into it. I can't believe how difficult
it is to actually find information about this. I talked
with many local, state, and federal employees and still
haven't found really concrete answers. The best information
I have so far on the subject is from David Coleman from
NHTSA whom I called today (3.16.05) Even finding his name
and contact info wasn't easy as I went through many people
before I found him.
NHTSA -
202.366.5302
David Coleman
NHTSA - 888.327.4236
Dept. of Customer Services:
523-4385
Below is what he told me - this is from my memory and notes,
so its NOT verbatim (but close)
NHTSA deals with motor vehicles on a federal level, states
do inspections and licensing. Under the National Traffic
and Motor Vehicle Safety Act, a "motor vehicle"
is defined, in part, as one that is "driven by mechanical
power."
NO kit car manufacturer can legally actually sell you just
a frame and provide a "real" MSO with a VIN number
on it. A VIN number is ONLY used for a rolling vehicle with
a powerplant. A kit without a powerplant is considered an
assemblage of parts, until it is rolling and has an engine
at which time it is a "mechanically driven vehicle."
Only about 7 types of certain manufactured parts fall under
regulation of the NHTSA, windscreens, seatbelts, brake fluid,
etc. Anything else and they don't even want to talk to you
about it...until the part breaks and someone is injured.
That then falls under their jurisdiction. They don't care
if your manufacturing candlesticks or anything else, unless
it is one of those parts. A reciept can be anything, it
can be written on toilet paper.
He said what some kit car manufacturers do is provide a
reciept, which they call an MSO (Manufacturer's Statement
of Origin) and as long as they do not include anything that
says VIN number, vehicle, car, automobile they do not fall
under the regulations of the NHTSA. (Interesting...)
He also said if a manufacturer does make a rolling powered
chassis it is then a motor vehicle which then falls under
all the federal regulations for crash tests, airbags, saftey
bumpers, etc. Unless you are manufacturing a rolling powered
vehicle, you cannot assign anything a VIN number.
He showed me numerous websites to search and find additional
information, which I've listed below. He said all 50 states
have some way to deal with "specially constructed vehicles"
there are 4 terms which the states use. (See below) Many
times you will not be able to register a "car"
you built, but when you say: "Specially constructed
vehicle" well...thats an entirely different thing.
--------------------------------
Links he showed me:
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SEARCH:
NHTSA for "kit car" AND "assemblage"
you may have to paste this in:
http://www.nhtsa.dot.gov/sssearch/Right.asp?advanced=yes&ct=Interps&ct=InterpsGM&Q1="kit+car"+AND+"assemblage"&c2=@filewrite&o2=>&q2=&Search=SEARCH
The two documents I found the most interesting are:
A
letter from Chief Counsel NHTSA - "There are no
specific regulations that a seller of kits must follow in
order to begin sales. "
and
Another
letter this time to Kent Morris -
"Kit cars, especially those manufactured from a combination
of new and previously used parts, have presented problems
of interpretation for the agency from the beginning."
"As no qualifier is used in the definition, a "manufacturer"
is any person assembling more than one motor vehicle, whether
or not the parts are new."
--------------------------------
AAMVA
- (American Association of Motor Vehicles) Search page -
Search for: "specially constructed"
The AMAMVA policy positions 2004 has some interesting information.
There is also a page on their site specifically about MSOs
or MCOs (Manufacturer's Cerificate of Origin). Actually,
I went to this page very early on. There isn't too much
information here, mostly about the very strict printing
procedures for a "real" MSO/MCO. But, by contacting
the printers (American Bank Note) listed on this page I
eventually came in contact with David above. I had previously
contacted the NHTSA, but not the correct person.
The American Bank Note company sent me more information
in this document.
They actually print MSOs/MCOs, the last page of the PDF
has a sample. It also has contact information for:
SAE - Society of Automotive Engineers
Cathy Douds
724.772.8511
douds@sae.org
She is the WMI Coordinator and works with VINs. I believe
specifically with Manufacturer's codes for NEW motor vehicles.
When I talked with her, and mentioned kit car frames, she
gave me David's information at the top of this page. Again,
as a frame is not a motor vehicle, she couldn't help out
with info on VINs for something that can't have one.
SAE - Search "kit
car" or "specially constructed"
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Each of the 50 States use at least on of the following
terms for kit cars: (each is of course different)
- Specially constructed vehicle
- reconstructed
- salvaged
- assembled "from parts"
State sites are in this format:
http://www.state.ks.us/
You can change the "ks" to the 2 letter code
for your state. Search for one of the 4 phrases above.
For the state of Kansas David pointed me to this document:
Which is the Specially constructed vehicle affidavit for
Kansas.
Remember, a kit car company can put anything they want
on a reciept, including MSO (Manufacturer's Statement of
Origin) As long as it doesn't say:
- Vehicle Identification number
- Vehicle ID Number
- Auto
- Automobile
- Vehicle
- Car
It CAN have a model number or a serial number.
MISC HAWAII MSO
Budget and Fiscal Services Dept.
523.4617
Was Dept of Finance?
Will
Espero is one of the Senators that sponsored the bill
for Hot Rods and kit cars in Hawaii.
His office number: 808.586.6360
Email: senespero@Capitol.hawaii.gov
DOT in Hawaii
808.532-4324
808.733-2530
Motor
Vehicle Registration Forms for Hawaii
City
and County of Honolulu website
If you see any errors in the information I have gathered,
or have additional information, let me know.
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