Interpretation ID: aiam3285
Assistant General Manager
Isuzu Motor America
Inc.
21415 Civil Center Drive
Southfield
Michigan 48076;
Dear Mr. Abe: This is in response to your letter of April 3, 1980, concerning th application of Federal Motor Vehicle Safety Standard No. 115 to incomplete vehicles.; S4.1 of Standard No. 115 provides that '(e)ach vehicle manufactured i more than one stage shall have a VIN and check digit assigned by the incomplete vehicle manufacturer.' Consequently, Isuzu Motors, Inc. would be the entity responsible for assigning the vehicle identification number (VIN) to incomplete vehicles which it ships to the United States.; You wish to know whether the manufacturer identifier in the VIN of eac of these vehicles may designate the vehicle as a 'truck' instead of as an 'incomplete vehicle' if Isuzu knows that the complete vehicle will be a truck.; S4.5.1 of the standard provides that the first three characters of th VIN shall identify the manufacturer, make and type of vehicle. Table I of S4.5.2 delineates the different types of vehicles and includes a separate type designation for 'incomplete vehicles'. as explained in the preamble to Notice 8 (March 22, 1979, 44 FR 17489, at 17490), the 'incomplete vehicle' category was added because 'incomplete vehicle manufacturers would have little way of knowing the final configuration of the vehicle they produce.' It was never the intent of the agency, however, to preclude a manufacturer from indicating the precise types of completed vehicles if this is known.; Sincerely, Frank Berndt, Chief Counsel