As we reported earlier (http://www.dealernews.com/dealernews/Breaking+News/PennDOT-Stops-Deliveries-of-Chinese-Bikes/ArticleStandard/Article/detail/564901?contextCategoryId=2704), PennDOT forbids dealers from issuing temporary tags for two- and three-wheeled Chinese vehicles. Dealer must send all paperwork to Harrisburg for examination. The process reportedly takes weeks. A customer can't ride the vehicle home until the permanent tags arrive.
The new process took effect in mid-September, PennDOT says, not at the beginning of the month as we reported earlier. Much of the paperwork has failed due to improper filing of the VINs and manufacturers' certificates or origin. Importers are trying to remedy the situation, but the federal government has been slow to update its database.
Seemingly inscrutable is the reason PennDOT gives for its not being able to exclude vehicles that have already passed the examination process: "There is not a list of compliant vehicles since in many cases each manufacturer uses different makes and model names to identify vehicles they handle," it says.
Also confusing is why PennDOT contacted only two automotive associations about the process. The only other notification was a bulletin posted on its website. Unfortunately for dealers, having such bulletins e-mailed to them is not an option.
We contacted PennDOT soon after learning of the situation. The department declined a phone interview, but it did send us the aforesaid statement in response to our questions. We publish the entire statement below:
PennDOT implemented an additional step in the review process, effective mid-September 2008, due to an issue PennDOT identified with Manufacturer's Certificate of Origin (MCOs) for two and three-wheeled motorcycles, motor-driven cycles, motor scooters and motorized pedal cycles (Mopeds) with a vehicle identification number (VIN) beginning with the letter "L." Utilizing the National Highway Traffic Safety Administration (NHTSA) online verification tools for approved manufacturers, PennDOT determined, and verified with NHTSA, that the MCOs of these vehicles and/or VIN configurations did not meet the National Highway Traffic Safety Administration (NHTSA) filing requirements.
This is an important consumer protection issue since a non-NHTSA filed MCO and/or an incorrect VIN configuration could make it very difficult for the consumer to identify the vehicle's manufacturer if it became necessary for NHTSA to issue a safety recall for these vehicles in the future. Ultimately this could negatively impact a customer and/or dealer of these vehicles from a liability standpoint. When PennDOT determined that NHTSA's filing requirements with these vehicles were not being met, PennDOT immediately added an additional step in its review process. If PennDOT receives an MCO that is determined not in compliance with NHTSA filing requirements, i.e. the MCOs do not reflect the correct VIN number and manufacturer, PennDOT rejects the title/registration application.
Those MCOs that are in compliance with NHTSA filing requirements are processed immediately and returned to the dealer. There is not a list of compliant vehicles since in many cases each manufacturer uses different makes and model names to identify vehicles they handle. Likewise, there is not a list of manufacturers whose VINs are noncompliant since the vehicle manufacturer is responsible for establishing the VIN configuration and properly documenting VIN decoding information to NHTSA.
PennDOT is working with dealers in Pennsylvania to address the proper titling and registering of these vehicles. If applications submitted for title and registration for these vehicles do not comply with the NHTSA filing requirements, the applications are being returned to the customer along with a letter explaining that PennDOT is unable to title and register the vehicles until the paperwork and VIN information is corrected by the manufacturer to meet the NHTSA filing requirements. Through this letter, PennDOT advises that the customer should contact the dealer/individual who sold them the vehicle to determine if they can provide assistance in obtaining a corrected MCO.
In the event the customer does not intend to resubmit their application for PA title/registration or the dealer cannot rectify the MCO issue, PennDOT includes a refund application along with the letter to the customer that they can complete in order to recover fees paid to PennDOT, i.e. title and registration fees.
PennDOT communicated these new requirements to dealers through its Driver and Vehicle Services Bulletin as well as sending out communications to the Pennsylvania Automotive Association and the Pennsylvania Independent Automobile Dealers Association.