Interpretation ID: aiam3515
Director of Engineering
Pathfinder Auto Lamp Company
6201 W. Howard Street
Niles
IL 60648;
Dear Mr. Nasby: This responds to your November 25, 1981, letter to Roger Tilton of thi Office regarding the applicability of vehicle identification number (VIN) requirements to trailer kits manufactured by your company.; It is our view that these trailer kits must comply with the VI requirements of FMVSS 115. Your kits contain all components necessary to assembly a complete trailer, and are advertised as capable of being readily assembled with simple tools such as screwdrivers and wrenches. We see no relevant basis for distinguishing between such kits and completed trailers for purposes of determining the applicability of FMVSS 115.; While the VIN requirements do provide anti-theft benefits, they als are important to this agency in administering the defect recall program as well as to State motor vehicle departments and insurance companies. Further, even if this agency exempted trailer kits from VIN requirements, purchasers of your kits would likely face difficulties when they attempt to register their trailers with the States. We expect most states to soon begin checking VIN's as part of the vehicle registration process, and vehicles without a VIN or with a nonconforming identification number might face rejection by the state motor vehicle departments notwithstanding a technical exemption from NHTSA. We feel that in the long run, the best and simplest solution is for vehicle manufacturers to assign a VIN which meets the requirements of FMVSS 115.; Should you still wish to seek an exemption from the standard procedures for obtaining exemptions are set forth in Title 49 of the Code of Federal Regulations, Part 555, a copy of which is enclosed. Such exemptions are available for not more than three years.; You should also be aware that certification labels must contain bot the month and year of a vehicle's manufacture. See 49 CFR 567.5(b)(5). The copy of the label you sent us contains only the year of manufacture.; If you have further questions on this matter, feel free to contact u again.; Sincerely, Frank Berndt, Chief Counsel