Transport Canada on kit cars

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There are a few pages on the Transport Canada (TC) site relevant to the subject of kit cars.

  1. The first is entitled “Kit Cars” in Canada
  2. The second is Frequently Asked Questions for Kit Cars.

First article: Kit Cars in Canada

Manufacturing and importation of kit cars

Following a brief preamble addressed at those who might manufacture or import kit cars into Canada, and/or amateurs who might wish to build one, which gives the impression that we will ultimately find out the boundaries and restrictions on these activities, we find this paragraph:

If you want to import a kit car or a reproduction vehicle that can be driven, you must provide proof that it meets all passenger car class CMVSS [i.e. Canadian Motor Vehicle Safety Standards] before importing it. There is no difference, under the Act, between assembled and disassembled vehicles. Note: Most kit cars do NOT qualify. Therefore, kit cars cannot be manufactured to sell in Canada or imported into Canada.

The internal inconsistency in the last two sentences (i.e. ‘most do not qualify’ :: ‘kit cars cannot be manufactured or imported’) ensures that getting a clear response to one’s questions is ruled out, but it would appear that the short answer for anyone who wishes to manufacture or import kit cars is simply: ‘no’.

Amateur building on the basis of imports

For amateur purposes, an imported kit is likely to pass customs provided that

  • the kit qualifies as a parts shipment/starter kit, meaning that it does not include any of
    • fuel system
    • brake system
    • power train
    • suspension system
  • the kit is not assembled (the body and frame are separate)
  • the wiring harness, steering system and interior parts are not installed (with the possible exception of the windshield, some trim and the instrument panel).

In order to obviate potential problems, TC recommends obtaining a detailed parts list in advance and sending it in to them for vetting prior to making any financial commitment.

Second article: Frequently Asked Questions

Salient points from the Q and A in this article:

  • the definition of starter kit (see above) is clarified as parts containing ‘only a bare frame and a body shell, with no mechanical parts’
  • TC has no jurisdiction within provincial borders, which is why in some cases kit cars can be manufactured and sold within provincial boundaries (though they may well then be ‘marooned’ there).

This document is not altogether devoid of illogic either. With regards to vehicles tested for single vehicle approval, we learn that

  • where such vehicles comply ‘with only those Canadian Motor Vehicle Safety Standards (CMVSS) listed in the Single Vehicle Approval Testing (SVA) manual’ (emphasis mine), they can only be imported if
  • they also comply ‘with those CMVSS that are not listed in the SVA’.

Just think about it.

Summary conclusion

It appears on the basis of these documents that as far as TC is concerned, only bare bones kits can be imported, to be supplemented by undercarriages ‘sourced in Canada’. On the other hand, TC has no provincial jurisdiction, so in essence its regulations bear for all intents and purposes only on import, that is, cross-border issues.

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