ROPS deficiency of gray-market tractors

Many used tractors that are imported from Japan are adding to the current national inventory in the U.S. and Canada of farm tractors that lack a rollover protective structure (ROPS). Gray-market tractors are built for use by the manufacturer for a certain country but are imported against the manufacture's wishes to a second country for use there, usually as a used tractor. Gray-market tractors may lack ROPS and seatbelts, depending on the date of manufacturer. The objective of this investigation is to describe the gray market for tractors imported from Japan into the U.S. and the policy implications regarding the hazards associated with these imports. Operator manuals and warning labels are typically not written in English. Foreign manufacturers that market tractors in the U.S. have established a variety of disincentives for the importation of gray-market tractors, including issuing warnings, not servicing or providing parts for these tractors, and banning their importation through actions by the U.S. International Trade Commission. Nonetheless, a U.S. market has developed that imports and provides services and parts for gray-market tractors, and some companies provide certified ROPS on the tractors that they sell. A product safety perspective and related policies are presented as an approach to ensuring that these imports are equipped with ROPS and seatbelts.