March 15, 2016
Global Automakers has submitted comments on a notice of proposed rulemaking (NPRM) issued by the Department of Energy (DOE) published December 29, 2015. In the NPRM, the DOE proposes that importers of certain products subject to an energy conservation standard provide, prior to importation, a certification of admissibility to the DOE. While Global Automakers believes the statutory authority cited by the DOE does not cover the auto industry, there is ambiguity because a table included in the proposed rule suggests these requirements may apply to a large number of motor vehicle parts as well as vehicles classified under HTS 8703 and 8704. Global Automakers requested that DOE clarify that the NPRM does not apply to automobile or automobile parts.