Interpretation ID: aiam3090
Safety & Emission Control Engineering
BMW of North America
Inc.
Montvale
New Jersey 07645;
Dear Mr. Ziwica: This is in reply to your letter of May 16, 1979, to Mr. Schwartz of m office, and in confirmation of your subsequent telephone conversation with him.; You wish to know whether Federal Motor Vehicle Safety Standard No. 115 *Vehicle identification number*, permits BMW to use all the permissible numerical digits in the 11th position of the vehicle identification number (VIN) for each of its two plants, as long as each VIN in its entirety assigned to each individual vehicle uniquely identifies its plant of manufacture. A system such as you suggest was proposed in the notice of proposed rulemaking for this standard issued on January 16, 1978 (Docket No. 1-22, Notice 4, 43 FR 2189). The response to this particular proposal was negative, and the rule issued on August 17, 1978, withdrew it. Consequently, the 11th character of the VIN must in and of itself be decipherable into the plant of manufacture (S4.5.3.2).; This is not to say, however, that BMW does not have considerabl flexibility in its utilization of the 11th position. A pointed out in Notice 8 (44 FR 17489, March 22, 1979), BMW can submit more than one character to represent a single plant. While this restriction unfortunately may result in some change to the system which BMW is currently employing, the agency believes that a sophisticated allotment of sequential blocks will alleviate at least some of the problems which you foresee.; Sincerely, Frank Berndt, Chief Counsel