This letter is JAMA's response to Docket No. NHTSA-2007-28104, proposed extension by the National Highway Traffic Safety Administration (“NHTSA”) of its data collection from motor vehicle manufacturers relating to the country of origin of equipment in new passenger motor vehicles, pursuant to the American Automobile Labeling Act (“AALA”).

Due to its length (seven pages plus attachment), the entire letter is being made available only as a PDF file. The following are excerpts from the letter:

AALA requirements are burdensome, misleading, outdated, and unjustifiable in today’s global manufacturing setting. AALA does not achieve its stated intent of informing the consumer. Instead, AALA works against that objective by deceiving the consumer. No legitimate U.S. interest is served by such an outcome. [page 6]

AALA creates burdens that adversely affect auto manufacturers. Because of the unjustified burdens these regulations create, they should simply be repealed. The law is so hopelessly defective and weighted against any meaningful or accurate depiction of the true content of a vehicle that it is arguably impossible to improve. Moreover, there is no need for AALA requirements, since other vehicle content regulations are already in place and provide a far more accurate accounting of origin, e.g., CAFE or NAFTA requirements. [page 6]

The entire letter is available as a PDF file [359KB]. Click here to view the file (right-click to download).