FMVSS Sticker Question

[BritshIron]

Dear @HBChris I guess I’ll offer you another view point on the location of the FMVSS labels in early 02 cars. My 1560629 1600-2 was made in September 1967, but imported through Hoffman and first sold at Peter Pan Motors in South San Francisco in early January, 1968. See photo of FMVSS label below. This is an early “Federalized” car, complete with air pump and odd ball exhaust manifold designed to more completely combust emissions.

 

No doubt Steve is the expert, but I think his main point in the last post is the DOT/EPA labels, addressing air quality concerns, are completely separate from the FMVSS labels, which certify a whole host of safety requirements are met at the time of manufacture.

As an aside, I’m sure people glaze over these label distinctions, and thus not everyone realizes there are two mandatory labels, addressing two separate US laws and requirements.

 

Thanks again for all your help. Much appreciated! Robert 

 

 

[Mark92131]

2 hours ago, BritshIron said:

As an aside, I’m sure people glaze over these label distinctions, and thus not everyone realizes there are two mandatory labels, addressing two separate US laws and requirements.

 

Early cars, imported by Hoffman had 2 stickers, one for Safety Standards, one for emissions.  At some point, 1970?, Hoffman imported cars dropped the Safety compliance sticker (pictures of early emission stickers, no safety compliance sticker) and later added compliance language for emissions HEW/EPA and CA ARB (CARB), and the year.  These "year" stickers started out silver, went to Black sometime in 1972 and later changed back to silver with perforations in 75/76.

 

Cars that weren't imported by Hoffman and later BMW (grey market cars) were impounded at the port of entry until they were certified by a licensed provider of inspection and modification services that all US safety and emissions equipment was present and working for that year of manufacture.  Those cars received a FMVSS label from the licensed provider (Like the one you have for Mr. Hand).

 

Now Hoffman may have imported some 1600/2002 Cabs for some select clients and the silver emissions sticker on Katy Perry car (pictured) is the earliest I have seen with a date, (1970).  I suspect that the Katy Perry Cab was a Hoffman import because it has the right emissions sticker (cars imported prior to December 1970 would conform to the US Department of Health, Education and Welfare (HEW) and after 1970, would conform to the EPA which assumed many of the HEW's programs) and it doesn't have 3rd party FMVSS sticker which would indicate it was imported as a grey market car.

 

I would love to see more photos of 1968 and 1969 cars with emission stickers to see if we can figure out approximately when the Safety sticker was dropped and a 1971 emission sticker to see if it has the EPA or HEW conforming statement.

 

Mark92131

[BritshIron]

@Mark92131 Your above post is just terrific. I'll do some research using Bring A Trailer archive photos and see if I can find more 1968 and 1969 cars with emissions stickers.

 

I sure thought ALL US import cars (and our US made cars) were required to have (specifically) a FMVSS certification label. For cars that don't, do you think the owners point to the silver DOT/EPA emissions sticker and claim that to be enough to prove the car was built for the US market? For those States which require the FMVSS label, I just can't see how the silver label cuts the mustard.

 

Back later with some pictures, I hope. Absolutely great stuff above. Many thanks! Robert

[Mark92131]

19 minutes ago, BritshIron said:

For cars that don't, do you think the owners point to the silver DOT/EPA emissions sticker and claim that to be enough to prove the car was built for the US market?

 

Yes, I think by 1968, BMW was considered a verified manufacturer of cars for the US market and the need for the US Safety sticker was no longer required.  The Emission sticker provides that the US Department of the EPA/HEW and the California Air Resources Board have tested and are happy with the emissions for the year of manufacture.  I'm not sure why a particular State would require a FMVSS label, unless it was a model or Vin # that wasn't officially imported to the US by the manufacturer.

 

Mark92131

[BritshIron]

Read this and weep! I honestly don't know the legislative history, but this regulation seem to be specific to Hawaii County, therefore only the Big Island. Hawaii registers and licenses it's cars based on County regulations. Word is to avoid the City and County of Honolulu's registration process, but not sure how much more draconian it could be!

 

I looks to me like Idaho has a similar FMVSS placard requirement. People on the web sure complain about it. Title 49-107 of Idaho's vehicle code: 5)  "Federal motor vehicle safety standards (FMVSS)" means those safety standards established by the national highway traffic safety administration, under title 49 CFR part 500-599, for the safe construction and manufacturing of self-propelled motorized vehicles for operation on public highways. Such vehicles as originally designed and manufactured shall be so certified by the manufacturer to meet the federal motor vehicle safety standards or the standards in force for a given model year or as certified by the national highway traffic safety administration.

 

It looks like Nevada and New Hampshire require FMVSS certification labels too, but I did not do a deep dive into those states. A depressing subject! 

 

 

Here's the language from Hawaii County regulations:

"All vehicles applying for registration in the County of Hawaii must be in compliance with all applicable Federal Motor Vehicle Standards as of the date of manufacture as required by Hawaii Revised Statutes 286-42.  Non-compliant vehicles such as off road motorcycles, off road motor vehicles (including ATV's), some military vehicles, imported vehicles, kit cars and modified vehicles may not be registered in the County of Hawaii.  Contact Motor Vehicle Control Inspectors at (808) 640-7339 or (808) 640-7342 for more information or further assistance on the Federal Motor Vehicle Standards."

 

And Wisconsin too! Could have sworn California has a similar requirement. Aloha! Robert

Title and registration for foreign (gray market) vehicles in Wisconsin

• Online services
• Vehicles
• Plate guide
• Special plates
• Motor carriers
• DMV customer service centers
• Forms
• Drivers

A foreign vehicle is defined as being manufactured for use in another country and not intended for use in the U.S. or as a vehicle last titled in a foreign country. Federal law requires that the title and registration of foreign vehicles must show that they meet U.S. standards, by either a Federal Certificate Label (FCL) or Registered Importer label (RI).

Federal certification label (FCL) manufactured to U.S. standards	Registered Importer label (RI) brought up to U.S. standards
Vehicles originally manufactured to U.S. standards will bear a manufacturer’s FCL stating that it conforms to Federal Motor Vehicle Safety Standards (FMVSS). An automobile, light truck, low speed vehicle or motorcycle of model year 1970 or newer must have a manufacturer’s FCL certifying the vehicle was manufactured for U.S. on-road use.	Vehicles manufactured for use in a foreign country can be imported into the United States and brought up to U.S. standards with the placement of a RI label. The RI label identifies the RI importer and their certification that the vehicle complies with all Federal Motor Vehicle Safety Standards (FMVSS) for that vehicle.

 

[Mark92131]

1 hour ago, BritshIron said:

For those States which require the FMVSS label, I just can't see how the silver label cuts the mustard.

 

It appears the FMVSS Safety and Emissions compliance wording was re-introduced on the 75/76 perforated VIN labels on the door jam.  Possibly when the legislation started cracking down on grey market cars?

 

Mark92131

[jimk]

The government in Hawaii never has had an original idea.  They only do what California does. (I lived there 8 years and left to rejoin reality.)

[BritshIron]

@Mark92131 Here's a few labels with year, model, and VIN I cobbled from Bring a Trailer archives. These are only 1600-2 sedanas from 1968. I'll take a look at 2002 cars from 1968 and 1969, as well as finish up the 1600-2 cars from 1969. Hope this helps! Robert

 

1968 1600-2, VIN 1561283

 

Below 1567485, 1968 1600-2

 

Below 1560529, 1968 1600-2

 

Below, 1563974, 1968 1600-2

Below, 1968 1600-2. No VIN number mentioned.

 

To be honest, I don't see a pattern. Some cars have "stacked" FMVSS labels on top of Emissions label. Others just Emissions label. Maybe a hit and miss Hoffman deal? I'll post more examples later. Aloha, Robert

 

 

 

 

 

 

 

 

 

 

 

 

[autokunst]

Hello Robert,

I just tried sending you a photo, but the app said I you are unable to receive messages.  I don't think my photo will add to your study, but maybe another data point.?.

 

I'll try via email.

Stephen

[BritshIron]

Stephen, I'll look for your photo on email. Be sure to include VIN and year. Every little bit helps! Mahalo! Robert

[BritshIron]

@Mark92131 Here's Stephen's FMVSS and Emissions label. More later. Thanks, Stephen! Robert 

 

Build date February 28, 1968 1600-2.  This was imported by Max Hoffman.  VIN 1563410.  Steven believes the engine bay to be original.

 

[BritshIron]

@Mark92131 I think you and the crew will enjoy this post. I sure learned something. As expected, none of the voll cabriolets or European sedans had either FMVSS labels or Emissions labels. One aha moment with a silver door emissions tag. Have fun! Apologies for any duplications, as well as some pictures that simply were of interest to me, without annotations. Aloha, Robert

 

Below, 1969 1600-2, VIN 1570181. Interesting, a 157XXXX VIN!

 

Below, 1969 1600-2, VIN 1568207

 

Below, 1968 2002, VIN 1664255.  

 

Below, 1968 2002, VIN 1661955. Note the FMVSS and Emissions labels are in reverse, stacked order when compared to others.

 

Below, 1968 2002, VIN 1667153

 

Below: 1969 2002, VIN 1666934

 

Below, 1969 2002, VIN 1664730

 

Below: 1969 2002, VIN 1665285. This car has some sort of silver sticker on the trailing edge of driver's door, but can't read it!

 

Below, 1969 2002, VIN 1666934

 

Below: 1969 2002, VIN 1668737. This car has a silver FMVSS label on trailing edge of driver's door. But no emissions label. 

Another look at the FMVSS label on 1969 2002, VIN 1668737. I suspect this label is from a compliance provider, an aftermarket item?

 

Below: 1969 2002 VIN 1662319. Another car where FMVSS and Emissions label are stacked, but reversed in order from others.

 

Below, 1969 2002, VIN 1665285. Note the silver FMVSS label mounted on door jam. This is the true AHA moment!

No emissions label on this car, just the silver FMVSS label affixed to the door jam, above.

 

 

 

 

 

 

 

[Mark92131]

12 hours ago, BritshIron said:

Below, 1969 2002, VIN 1665285. Note the silver FMVSS label mounted on door jam. This is the true AHA moment!

 

Yes, but instead of "AHA" more like "WTF"!  Strange that it is a 75/76 style FMVSS security label without the date and Vin # stamping on a 1969 2002.  Maybe you could order these from BMW and stick it on your car if you were trying to get it registered in a state that required a valid FMVSS sticker.  I don't know. 

 

Thanks for compiling the examples, I think it is also interesting that some of the early FMVSS stickers reference the USA - Federal Register Part 255, effective January 1, 1968 while others just reference the time of manufacture and it doesn't seem to have any relationship to when the car was built, (1969 2002, VIN 1666934 for example).

 

Mark92131

 

 

[BritshIron]

@Mark92131Yes, there are subtle word changes on many of the labels as the years go on. Regarding the very rudimentary silver label on the 1969 2002 VIN 1665285, I can think of two things. One is maybe that's all that was required in 1969, and the law changed for the 1970 model year to produce labels like Carl's. The other is something @Conserv above mentioned--maybe the ink that was provided for that particular label was of the "disappearing" variety, and thus the VIN used to be on the silver label, but is now gone. One nice thing about having the annotated list above. You can go the the Bring A Trailer "search archives"window, and just type in (for example) BMW 2002 1661955 and the car cited above will pop up with full suite of pictures and other information.

 

All the best. What do you think about the odd FMVSS label on 1969 2002 1668737? Aloha, Robert

[HBChris]

That AHA door was probably replaced with a later door.  My 11/68 2002 had the black safety sticker next to the emission sticker as well, I forgot.  And stickers get replaced, see Stephen’s Battery sticker next to the Safety sticker, not correct and never placed there.  
 

I love to have the correct stickers but personally but I am now exhausted by this discussion!