Letter stating that my car complies with emission standards

73Polaris

73Polaris

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I recently purchased a 73 E9 from a person in Vancouver, Canada and imported it into the US, my home is California. I submitted registration paperwork and just received a letter from the DMV that they cannot process my registration until I provide the following:

A compliance letter from BMW indicating if the vehicle complies with all applicable US Emission Standards and/or California Emission Standards. The letter from BMW must confirm this information and this letter must identify my vehicle by the VIN.

Has anyone in Peoples Republic of California had to go through this process? Any ideas on where to start?
 

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It’s a recent change to the DMV regulations affecting all out of state vehicles built 68 and newer. Ask the BMW Archive for a letter but you should have the EPA/DOT sticker on passenger fender and a silver HMVSS sticker on trailing edge of driver’s door Which confirms compliance. They want to see both stickers and VIN verification can only be performed by the CHP. Good luck!

(and anyone in CA buying a car on BaT needs to be aware of this)
 
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Good morning from Muscat, Mr. L.
Exactly what they request can be done.... first you need a senior executive from BMW to write that letter on BMW letterhead. While that favor has been done on a Csl, it is likely unreasonable to ask for that on a Cs.
i have spoken with Coupeking on this for you and he recommended the Montana solution. I am forwarding CK contact info to you.
 
Wow, that really stinks. So if you get a car repainted in CA you MUST keep those stickers, or somehow preserve them? Or hope that they did not fall off or something?
 
This is what I would do:

Craft a letter to the BMW Archive, most likely Andreas, and provide a copy of the DMV letter which states that all imports of 1968 MY cars and newer are affected. Remind them that without their support the market for e9 coupes will be severely compromised in CA. Also, coupes can command over $100K and we aren’t even talking about the CSL, this is not a trivial issue. Remind them that Canada got the same configuration as the US, this even included side markers lights and 5 mph bumpers in model year 74. They may not even be aware of this!
 
Wow - this is well beyond the federal rules applicable to cars manufactured within the past 25 years. As I read the relevant CA state publication on this - HTRV 09A - the labels should be sufficient because is says "any" of the following are acceptable:

Emissions—Evidence of compliance with EPA and California emission standards. Any of the following are acceptable:

- An EPA and California emissions label affixed to the vehicle.
- A certificate of conformity issued by a CARB-licensed laboratory. No smog certification is required if this document is submitted for original registration.
- A letter from the manufacturer stating the vehicle complies with FMVSS and U.S. emissions requirements (usually only attainable for vehicles from Canada).


Moreover, and I hate to sound pessimistic, but it appears that the manufacturer letter rule is designed to be useless. The manufacturer letter requirement says that the manufacturer must state that the vehicle "complies" with all applicable U.S. emissions standards and/or California emissions standards. The publication and your letter both use the present tense of the verb "comply"; meaning the vehicle must comply now. The most you can expect from a manufacturer is a letter stating it was designed and built so as to meet the US and CA emissions requirements at the time it was manufactured.

If I were in your shoes, I would write back to the DMV Technical Compliance Section, and point out to them the problem with the verb "complies." I would then ask why the letter is necessary when the publication says that the stickers are sufficient. Send pictures of the stickers. Ask if there is a procedure for a DMV office to confirm that your stickers are present.
 
HB Chris said:
It’s a recent change to the DMV regulations affecting all out of state vehicles built 68 and later. Ask the BMW Archive for a letter but you should have the EPA/DOT sticker on passenger fender and a silver HMVSS sticker on trailing edge of driver’s door Which confirms compliance. They want to see both stickers and VIN verification can only be performed by the CHP. Good luck!

(and anyone in CA buying a car on BaT needs to be aware of this)
Click to expand...
We are planning to retire to our house in Sonoma in a few years. If I understand correctly my 74 US spec coupe converted to e12 L-jet injection installed will not be legal in CA?
 
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