It's just not true - the author of this article doesn't understand FMVSS or the process.
How this works is basically:
1) There are safety guidelines (FMVSS) governing classes of motor vehicles. For LSVs, the regulations are _extremely_ simple. There's no such thing as a "DOT reverse camera factory." https://www.law.cornell.edu/cfr/text/49/571.500
2) The manufacturer must self-attest that the vehicle complies, and affix a label confirming this self-attestation.
That's pretty much it. Now the NHTSA will do what they need to to enforce their rules. If customers complain or independent testing reveals a violation, they will require a recall or ban certain vehicles or makes, or sue the manufacturer or importer.
But there's no reason these vehicles couldn't be compliant if the manufacturer was willing to attest, and also no such weirdness as "DOT factories."
I'm the author of that article, and it is true. You've linked to the correct law, but you didn't read it fully. Even if we drill down on a single item, like the backup camera you mentioned, then a more careful reading of the law shows the full requirements.
There you can see the reverse camera requirement is as follows:
"(11) Low-speed vehicles shall comply with the rear visibility requirements specified in paragraphs S6.2 of FMVSS No. 111."
Follow that through to the full requirements for backup cameras in FMCSS No. 111 and you'll see that the LSV backup camera requirements are the same as the backup camera requirements for full motor vehicles. That includes that the factory that produces it is registered with the NHTSA. It's not enough for the chinese factory to claim that they meet the camera depth of field requirements, angle of vision requirements, color requirements, etc. They have to be registered with the NHTSA, after which they will be listed in the DOT database for registered manufacturers, as well as produce the product to those specific standards. So yes, there very much is a such thing as a "DOT reverse camera factory." If you consult the DOT's own online database, you'll find all of them listed.
Millions of things are stamped "not for highway use" not because they don't comply with the relevant FMVSS but because the manufacturer doesn't know, doesn't care and doesn't want to think about it or risk being wrong.
Absolutely, and for the "full" FMVSS this makes sense - the stakes are high and the rules are a byzantine mess in a lot of areas (for example, making sure specific warning lights aren't obscured at each possible angle of a telescoping and tilting steering column).
But, for LSV the requirements are so simple that this is much easier, though.
This is not correct. You're part way there. Things like "have lights, DOT windshield, DOT seat belts, doesn't go over 25 mph" etc are all in fact requirements. But those are the simple ones. The trickier ones are what keep most of these from being street legal. The noisemaker has to meet all the FMVSS requirements of noisemakers in full electric cars like Teslas, Nissan Leafs, etc. The backup cameras have to meet the full FMVSS requirements for backup cameras in all full size cars. Even the factory doing the assembling has to be registered with the NHTSA and have a WMI - it's not enough to build your own factory and self certify. If you don't have NHTSA registration, a WMI and vin numbers that match a specific decoding sequence on file with the NHTSA for your specific factory (Which is why your factory has to be registered with NHTSA), your LSVs aren't street legal at the federal level and can't be imported to the US legally for on-road use if produced abroad. This is all in the document you've linked, you just haven't followed through to the sections listed in each requirement to see what the specific requirements actually are.
Importing EVs to the US at any decent scale would be a big can of worm. At least until there’s serious US produced competition in that specific segment. Japan cars getting publicly bashed was 40 years ago; times have changed, but touching the auto industry is still a pretty emotional topic for a lot of people (coughTesla fanscough)
> Millions of things are stamped "not for highway use" not because
And those things cannot be registered to be driven on public roadways. That's going back to the beginning of the discussion - this truck cannot be registered to be driven on public roadways.
How this works is basically:
1) There are safety guidelines (FMVSS) governing classes of motor vehicles. For LSVs, the regulations are _extremely_ simple. There's no such thing as a "DOT reverse camera factory." https://www.law.cornell.edu/cfr/text/49/571.500
2) The manufacturer must self-attest that the vehicle complies, and affix a label confirming this self-attestation.
That's pretty much it. Now the NHTSA will do what they need to to enforce their rules. If customers complain or independent testing reveals a violation, they will require a recall or ban certain vehicles or makes, or sue the manufacturer or importer.
But there's no reason these vehicles couldn't be compliant if the manufacturer was willing to attest, and also no such weirdness as "DOT factories."