Interpretation ID: aiam3128
Toyo Kogyo Co. Ltd.
P.O. Box 18
Hiroshima
730-91 Japan;
Mr. Matsui: This is in response to your letter of May 11, 1979, requesting th National Highway Traffic Safety Administration's (NHTSA) views on whether the inclusion of optional equipment on certain Mazda models would be sufficient to create a number of different series within that model.; Section 4.5.2 of Federal Motor Vehicle Safety Standard No. 115 (Vehicl Identification number) states that the second section of the vehicle identification number for passenger cars shall be decipherable into the vehicle's line, series, body type, engine type, and restraint system type. 'Line' is defined as 'a name which a manufacturer applies to a family of vehicles which have a degree on commonality in construction, such as body, chassis or cab type.' 'Series' is defined as 'a name which a manufacturer applies to a subdivision of 'line', denoting price, size, or weight identification, and which is utilized by the manufacturer for marketing purposes.'; Based in the facts presented, it is apparent that models equipped wit different optional equipment could each be designed a 'series' if Mazda desired. Nonetheless, the definition of a 'series' makes clear that the responsibility for applying and utilizing the 'series' designation rests initially with the manufacturer. If the difference between the potential series are superficial and a manufacturer chooses not to designate separate series for marketing reasons because of the superficiality, the agency will not require such a designation.; Sincerely, Frank Berndt, Chief Counsel