FMVSS Sticker Question

[autokunst]

38 minutes ago, HBChris said:

see Stephen’s Battery sticker next to the Safety sticker, not correct and never placed there.

Ouch.  I'd assumed that the engine bay was original.  but this car did have 54 years of adventures before it came home with me, so...  I do think it was "original" until some time between the early 2000s and 2009.  Somewhere around then, some work was done on the nose.  But again, I didn't think it extended into the bay/stickers.  I learn something new every day.

Edited July 17 by autokunst

[Mark92131]

7 hours ago, BritshIron said:

What do you think about the odd FMVSS label on 1969 2002 1668737?

 

Either a compliance company or an previous owner made up their own FMVSS label.  Copied the format of the 75/76 FMVSS sticker.

 

7 hours ago, BritshIron said:

maybe the ink that was provided for that particular label was of the "disappearing" variety

 

Those perforated 75/76 FMVSS stickers didn't use ink, the date and VIN # was created by BMW by punching holes in the label.  The label on the door of 1665285 is a blank one.

 

Mark92131 - Also exhausted!

[Conserv]

Count me among the exhausted, but…

 

We discussed the DOT/EPA-mandated door stickers at length, probably 10 years ago, focusing on the variations over time, from 1970 onward! These are the Federal Certification Labels (FCL’s) mentioned in the cite illustrated by Robert. Unfortunately, I cannot find the earler thread but…

 

Every single U.S.-spec ‘02 from the 1970 model through the 1976 model year got this sticker, the FCL, at the factory, even those ‘76’s which, like mine (they appear to have been February through April 1976 builds), that did not receive a riveted-on VIN tag on the right inner fender. This FCL was required for the car to pass U.S. Customs. Euro-spec cars did not receive these stickers at the factory. 

 

And there were at least four versions of the FCL, by which I mean the VIN-specific FCL. The first two versions have no letter in the lower right corner. A version introduced ca. 1974 has a “b” in the lower right corner. And the 1975-76 version has a “c” in the lower right corner. The first through third versions were inked with the VIN and build date. The “c” version may have started with the sadly-fugitive ink but converted at some point from ink to tiny perforated holes. They switched to the perforations when they realized that the inks they had been using since the 1970 model year were fugitive, fading away in a few years in some cases! The FCL you see may be missing its VIN and build date today, but it had both when it left the factory. Some versions today, although lacking all remnants of the original black ink show ever-so-slightly-indented ghosts of the VIN and/or build date, left by the printing process.

 

Again, every U.S.-spec ‘02 from the 1970 model year forward got this VIN-specific FCL. All of these stickers were silver. Many of them — maybe the second through fourth versions — were printed on scored stock (i.e., self-destructive if moved) so they could not be transferred between vehicles. More than a few cars have had drivers doors swapped from other ‘02’s — due to accident, not thievery — and today have FCL’s that do not match their VINs. An Inka 1973 tii currently on eBay displays this quirk, with a 253xxxx door and a 276xxxx title. Other cars received new replacement doors or were re-painted, and have no FCL’s at all.

 

There’s some discussion in the following thread, but it’s not the original thread discussing the FCL versions in depth!

Below, that sticker previously shown, VIN 2742541, is from my ‘76 (first photo below). And my ‘73 tii (Malaga over Inka 😯😳) has its sticker buried under an amateur repaint, ca. 1980’s (second photo below). Notice how the scored circles are emphasized by the Malaga overpaint… 😉

 

Enough — I’m even more exhausted now!

 

Best regards,

 

Steve

 

[Conserv]

By the by, the example shown below is the first version of the Federal Certification Label (FCL): silver with a black border. This car, manufactured October 1969, is a 1970 model year vehicle, the first year for which the VIN-specific FCL was required.

 

(Model years run from September through August.)

 

Best regards,

 

Steve

 

[BritshIron]

@ConservI really appreciate your work on your last post. I think I am now clear on some of the label differences. To me, the FCl label you refer to is indeed the FMVSS certification label, only by a shorter abbreviation. And in the case of my Baur and @Einspritz 02 Turbo, (Barry W. Taylor Enterprises Inc. label) we have Importers Labels (RI) which proves to anyone who may need to know that our respective cars have ostensibly been upgraded from former European standards in order to all US safety standards applicable in our year the two cars were manufactured.

 

I’m s

[Conserv]

Robert,

 

The clip you posted earlier, and which I re-post below, with my added highlighting, best sums up the situation: from the 1970 model year onward, a foreign-manufactured car in the U.S. shows it complies with Federal Motor Vehicle Safety Standards (FMVSS) by either:

 

1.   A Federal Certification Label (FCL), applied by the factory to cars manufactured to U.S. standards, or

 

2.  A Registered Importer Label (RIL), applied post-factory by a registered importer which has modified a car to meet U.S. standards.

 

Either 1. or 2. must be affixed to the driver’s side door or door pillar, as Chris pointed out. And I think we confuse matters by not distinguishing FCL from RIL. One is for cars manufactured to comply with FMVSS; the other is for cars modified post-factory to comply with FMVSS.

 

For the 1968 and 1969 model years, things are less clear, since a VIN-specific FCL had not yet been “invented”. Multiple versions of labels, all with white lettering on a black background, but without VIN’s or manufacturing dates, and without explicit model years, served to certify that a vehicle complied with FMVSS. It was a bit sketchy, not having a VIN, and without the scored stock to discourage “label swapping”… 🙄 

 

The most common arrangement of these early, VIN-less FCL’s is at the right end of the heating/defrosting air plenum, adjacent to the tuning sticker mandated by the EPA, commencing with the 1968 model year (which begins September 1967). Occasionally the early FCL was placed “under” the EPA tuning stick (second  photo), but generally it was placed “over” the tuning sticker (third through seventh photos). Photos borrowed from Robert, in this thread.
 

I don’t know if the requirement for an RIL applied or applies to those 1968 and 1969 model year vehicles. Others here, such as you, will likely know.

 

And before the 1968 model year, it’s not clear there was any labeling requirement. Since there were no real FMVSS, there was no need for all those bothersome labels. 
 

For the sake of clarity, I find “FMVSS Label” or “FMVSS Sticker” — both terms that I, and others, have used, to be overly broad and ambiguous. FMVSS is a set of standards. There are more specific categories of labels, FCL, RIL, and “some of the labels applied in 1968 and 1969,” each of which label denotes a different way of representing a vehicle’s compliance with FMVSS.

 

This is where I’m at, currently!

 

Best regards,

 

Steve

 

 

 

 

 

[BritshIron]

@Conserv At the risk of adding any more exhaustion to you or visitors to this post, I do have one more question. And this is not aimed specifically at Carl’s 1970 model year cabriolet, because I’ve found other former “European only” BMW passenger cars that were imported into the US and share this trait.

What about the cars which have a silver “sculpted” background label, mounted either under the hood or associated with a door surface, where the information on the label is only about compliance with US emission standards, but no mention on that label or any other label about FMVSS? I have some ideas, but: “Tis easier to be silent and thought a fool, than to open one’s mouth and remove all doubts!” See example photo below:

 

And while I’m concerned about the tedious and exhaustive nature of getting these small details right, it’s apparently in my DNA to know as much as possible about the history of these old machines that occupy so much of our car hobby time. I’m reminded of the George Patton quote, as he surveyed a spent battlefield and mused about the condition of the enemy:“I love it. God, I love it so.”

 

Thanks in advance for any more manao (Hawaiian for “wisdom.”) Aloha, Robert 

 

[Conserv]

On 7/17/2024 at 1:11 PM, BritshIron said:

@Conserv At the risk of adding any more exhaustion to you or visitors to this post, I do have one more question. And this is not aimed specifically at Carl’s 1970 model year cabriolet, because I’ve found other former “European only” BMW passenger cars that were imported into the US and share this trait.

What about the cars which have a silver “sculpted” background label, mounted either under the hood or associated with a door surface, where the information on the label is only about compliance with US emission standards, but no mention on that label or any other label about FMVSS? I have some ideas, but: “Tis easier to be silent and thought a fool, than to open one’s mouth and remove all doubts!” See example photo below:

 

And while I’m concerned about the tedious and exhaustive nature of getting these small details right, it’s apparently in my DNA to know as much as possible about the history of these old machines that occupy so much of our car hobby time. I’m reminded of the George Patton quote, as he surveyed a spent battlefield and mused about the condition of the enemy:“I love it. God, I love it so.”

 

Thanks in advance for any more manao (Hawaiian for “wisdom.”) Aloha, Robert 

 

Robert,

 

Are you referring to what I call “scored stock”: the stock on which the label is printed has scored circles everywhere — not cut entirely through, but cut sufficiently deep that any attempt to remove the label will cause it to disintegrate into tiny useless pieces?

 

This practice starts ca. 1970 and continues through the end of the ‘02 era. I see it primarily on the EPA tuning stickers (1970-72) and the FCL (Federal Certification Labels) (1971-76).

 

These are stickers that are not meant to be shared. The scored stock enforces that concept. They stopped using it on the EPA tuning stickers after some sharp person said, “Who would steal an EPA tuning sticker?”

 

Below, a montage of scored stock ‘02 labels…

 

Best regards,

 

Steve

 

 

 

[BritshIron]

Steve, your terminology is so much better—yes, scored stock. But some of these silver scored stock labels only have language related to emissions standards (EPA tuning standards if you will) and no language related to the host of safety standards, normally covered by an FCL. I guess my question, which is grounded in nothing but observations, is as follows:

 

Was there a time (maybe 1970-ish) when these cars came into the US legally, with the silver scored labels which contained language only applicable to US emission standards? And no other label or scored label language that covered the FCL mandates? It seems like a small group of cars were like this, but I was a college boy back then!

 

As usual, your knowledge and access to photos is just phenomenal. Thank you! RPS

[BritshIron]

@Conserv Last Tuesday within this thread you mentioned a thread that was maybe 10 years old, that covered this subject in great detail. I wonder if it’s the thread below? I can see you were a commenter, along with a guest claiming to be a California inspector!

My questions about “scored stock” silver labels that also apparently serve as the FCL, and scored stock silver labels that speak only to emissions requirements, are not aimed at either of my “Federalized” BMW cars (or in the case of the Baur cabriolet, ostensibly Federalized for import and fitted with an RIL). To this end, thank goodness I have the labels to pass muster under current Hawaii registration laws.

 

But it is really interesting to me that there seems to be a fair number of cars, from model year 1970 to at least 1972, that have scored stock labels that don’t seem to offer the information required on an FCL.

 

The older thread above seems to really emphasize the importance of FCL information (especially in California) as back-up proof for the matching VIN on the cars. I note with interest that the EPA/CARB information may be important in California, but the information required on an RIL for import is the FMVSS compliance information. It’s almost as if the air quality/emissions information is sort of important, but the FCL information is really important!

 

Anyway, this is all very interesting to me, even though to most it is pure minutiae! I just like for things to make sense, I guess.

 

Mea culpa if I’ve beaten a dead horse!

 

Aloha, Robert 

Edited July 21 by BritshIron

[Conserv]

14 hours ago, BritshIron said:

 

… But it is really interesting to me that there seems to be a fair number of cars, from model year 1970 to at least 1972, that have scored stock labels that don’t seem to offer the information required on an FCL…

 

Robert,

 

Allow me to expand your generalization. There are many ‘02’s, from the 1970 through 1976 model years, that retain their EPA tuning stickers but lack their Federal Certification Labels (FCL’s). And there is good reason for this: 50 years of history!

 

The EPA tuning stickers were placed in the far right end of the heater/defroster plenums. Thus, the stickers have few natural predators: (1.) comprehensive re-painting (and many people who commission comprehensive re-paints replace the tuning stickers post re-painting); and (2.) natural deterioration of the tuning stickers (The 1975-76 stickers seem to have been printed on notably-inferior stock. Still, their remnants survive.). All in all, they’ve survived quite well.

 

The FCL’s have more natural predators: (1.) replacement of or serious damage to the driver’s door (What percentage of doors have been replaced due to rust or accident? Given the demand for new and old replacement doors, that percentage is pretty darned high.); (2.) partial re-painting of the car, due to rust or accident; (3.) comprehensive re-painting of the entire car (but note that doors and door jambs are re-painted more often than heater/defroster plenums); and (4.) natural deterioration of the FCL’s. Recall that FCL’s, from 1971 through 1976 were printed on scored (i.e., self-destructing) stock. Thus, one can’t peel off the label and re-install it later. Further, once you’ve painted over the sticker (my tii is below), you’ll never remove the paint while preserving the original printing on the FCL. And… I suspect that 50 states plus the District of a Columbia — not to mention the Federal government — frown upon vehicle owners printing reproduction VIN labels: that would really open a can of worms. 🙄

 

Thus, there are probably significantly more surviving EPA stickers than FCL’s today. Both of my current ‘02’s retain their original FCL’s. But only one of them, that is a mere 50% of the population 😉, has a recognizable or readable FCL, and that’s my ‘76, which has had only a single owner! U.S.-spec ‘02’s, from the 1970 through 1976 model years, did not leave the factory without FCL’s!

 

Best regards,

 

Steve

 

 

 

[Mark92131]

45 minutes ago, Conserv said:

I suspect that 50 states plus the District of a Columbia — not to mention the Federal government — frown upon vehicle owners printing reproduction VIN labels: that would really open a can of worms. 🙄

 

Like this one? 😉

 

Mark92131

[Conserv]

18 hours ago, Mark92131 said:

 

Like this one? 😉

 

Mark92131

My attorney has advised me to not comment, Mark… 😯😉

 

Best regards,

 

Steve