Interpretation ID: aiam4422

Lawrence C. Bourbeau, Jr., Esq. Assistant General Counsel Fruehauf Corporation, Law Department 10900 Harper Avenue P.O. Box 238 Detroit, MI 48232; Lawrence C. Bourbeau
Jr.
Esq. Assistant General Counsel Fruehauf Corporation
Law Department 10900 Harper Avenue P.O. Box 238 Detroit
MI 48232;

Dear Mr. Bourbeau: This letter responds to your earlier inquiry wher you ask whether NHTSA would object to your Company's changing 'its model year designation from September 1 to July 1.' I apoligize for the delay in responding. Standard 115, Vehicle Identification Number- Basic Requirements, directs vehicle manufacturers to place a discrete identifying number (VIN) on each vehicle. Title 49 CFR Part 565, VIN- Content Requirements, states that a VIN must include a character indicating the manufacturer's designated model year. Neither Standard 115 nor Part 565 prohibits your company from changing the model year in the manner you suggest. Therefore, such a change does not violate our regulations. We note that this change apparently concerns model year as a marketing concept. The Federal Trade Commission has published guidelines concerning model year as a commercial concept, and you may wish to contact the Commission for whatever assistance it may provide. I hope you find this information helpful. Sincerely, Erika Z. Jones Chief Counsel;