Maybe it's just my ego, but I believe this memo issued by the CA DMV was in response to our attempt to register a 1970 Toyota Crown. They sent that memo out 2 days after we received a letter denying our registration. They say any direct import since 1966 that does not meet EPA requirements must contact CARB for certification.
We're currently compiling our case, and will be posting all about it tomorrow. Short version...Bureaucracy in California is even worse than I thought. They're attempting to stretch the definition of 'used direct import vehicle' to mean vehicles manufactured after 1966. Funny, since they define 'Used Direct Import Vehicle' as a vehicle manufactured after 1975...basically it's a fucking mess. This memo also directs DMV employees to not uphold the exemption that vehicles over 25 years old do not need to meet FMVSS as it's written in the California Health and Safety Code, and is currently in their manual!
I wonder if RM Auctions, and Gooding and Co. are aware they can't sell their Japanese Classics to a California resident? Actually according to this memo, it seems a lot of the cars up for auction every year in Monterey shouldn't be able to be sold there at all. After all it is illegal for a California dealer or auctioneer to represent a car for sale that does not meet certification requirements...according to Vehicle Code 24007 and 24007.5