Interpretation ID: aiam4199
Oshkosh Truck Corporation
P.O. Box 2566
2307 Oregon St.
Oshkosh
WI 54903-2566;
Dear Mr. Thekkanath: This responds to your letter dated May 9, 1986, regarding the placemen of the vehicle identification number (VIN) on heavy duty vehicles. You asked whether a heavy duty truck must have a VIN that meets the location requirement of S4.6 of the standard or whether the VIN for such a vehicle can be located on the vehicle certification plate. As discussed below, the VIN for a truck with a gross vehicle weight ratings (sic) (GVWR) of 10,000 pounds or more can be located on the vehicle certification plate.; Standard No. 115, *Vehicle Identification Number - Basic Requirements* requires passenger cars, multipurpose passenger vehicles, trucks, buses, trailers, incomplete vehicles, and motorcycles to have a VIN. S4.5 of the standard requires the VIN to appear indelibly on a part of the vehicle which is not designed to be removed except for repair or upon a separate plate which is permanently affixed to the vehicle. S4.6 of the standard specifies the location of the VIN inside the passenger compartment for passenger cars, multipurpose passenger vehicles, and trucks of 10,000 pounds or less GVWR. However, the VIN location requirement of S4.6 does not apply to vehicles with a GVWR over 10,000 pounds.; As you correctly noted, Part 567, *Certification*, requires the VIN t be located on the certification label of motor vehicles. Since S567.4(b) requires the certification label to be permanently affixed to the vehicle, the agency considers providing the VIN in this location as complying with the requirement of S4.5 of Standard No. 115.; I hope this information is helpful to you. Sincerely, Erika Z. Jones, Chief Counsel