Interpretation ID: aiam3276
Manager
Technical legislation
International Harvester Company
2911 Meyer Road
Fort Wayne
Indiana 46803;
Dear Mr. Krall: This is in response to your letter of April 3, 1980, requestin confirmation of the applicability ofS4.4 of Federal Motor Vehicle Safety Standard No. 115 (49 CFR 571.115) solely to light trucks and passenger cars.; Although Standard No. 115 applies to a variety of vehicle types including multipurpose passenger vehicles, the location requirements in S4.4 regarding the placement of the vehicle identification number is of more limited applicability. The section expressly provides that the requirement applies to passenger cars and to trucks with a gross vehicle weight rating (GVWR) of 10,000 pounds or less only. Since Standard No. 115 does not contain any other VIN location requirement, manufacturers of multipurpose passenger vehicles, buses, trailers, incomplete vehicles, and heavy trucks are not limited by that standard in their choice of a VIN location. For definitions of these vehicle types, see 49 CFR 571.3.; Sincerely, Frank Berndt, Chief Counsel