Spec for spec notwithstanding, the rule specifically calls your product out as illegal.
No it does not, Andy. The reg states:
It is not intended to allow parts that do not meet all dimensional and material specifications of new parts from the manufacturer...
...which has a clear Roffe Corollary implication that as long as the parts meet dimensional and material specifications as the original, they are compliant, to both ITCS and STCS.
Nowhere in the regs are these parts limited to exact logo and inking equivalents; if they were, then why specifically call out material and dimensions?
Remember, "
if it says you can, then you bloody well can!"
And, as I noted before, it is clearly against most copyright and patent law for any aftermarket parts manufacturer to produce a part that uses the exact same markings, logos, etc as the OE manufacturer; it is
impossible for
any aftermarket manufacturer to legally produce parts in that manner. There is not one aftermarket part in the world that would meet that requirement.
By arguing otherwise, Andy, you are attempting to change the intent of the aftermarket parts allowance and/or make it completely impossible to comply. The allowance would become moot.
There is a huge difference in the IT and ST rules here.
No there's not, Andy; they're exactly the same. Same IIDSYCTYC philosophy, same exact "you can only use cars and engines from the US market". The only difference is that STL allows the
opportunity for non-US engine
designs from other markets to be specifically approved.
But we're not talking engine
designs here, Andy; we talking individual component
parts, whose source is unregulated (insert George comment here...)
And in the end, if the individual parts from a JDM/EDM engine are completely indistinguishable from those in a USDM engine, why would anybody care where they came from? How does this is even come close to violating either the spirit of the letter of the regs?
Finally, I'm further offering that my position allows use of JDM/EDM engines as parts sources
in Improved Touring as well (I've done it, and I've explained to others how they can do it while staying compliant to the ITCS)
So this discussion has
absolutely nothing to do - zilch, zero, nothing, nada! -with the STCS's JDM engine allowance.
There is a better rule to be written here...
Nope, no rule re-write needed - and none will be pursued - simply because your position is based on faulty logic and mis-reading of the intent of the regs.
There is nothing here to "fix".
"Thank you for your input."
That is why I like 'USDM engine assemblies or their exact equivalent'or something like that.
Again, we're not talking engine assemblies. I think that's where you're getting all hung up. We're talking individual component parts, the sources of which are unregulated, as long as they're identical in dimensions and materials.
And...they are. Same exact parts.
- GA