Interpretation ID: aiam4313
Attorney at Law
P. O. Box 24
Courthouse Square
Ashville
Alabama 35953;
Dear Mr. Tucker: Your letter to the Society of Automotive Engineers (SAE) was referre to me for reply. Your letter informs SAE that a second trailer manufacturer, Nix Enterprises, Inc., is using the WMI Code designation SAE assigned to your client, Omni Trailers, Inc. You asked SAE to take whatever action it could to prevent the continued misuse of your client's WMI Code.; Under Federal motor vehicle safety standard 115, 49 CFR 571.115 (Standard 115), a motor vehicle manufacturer must assign a 17-character Vehicle Identification Number (VIN) to each vehicle it manufactures. The first three VIN characters must, among other things, uniquely identify the vehicle manufacturer. Among the primary reasons for the VIN designation are to facilitate vehicle notice and recall campaigns where a vehicle proves to be defective, and to aid persons investigating motor vehicle thefts or accidents.; The National Highway Traffic Safety Administration (NHTSA), an agenc of the United States Department of Transportation, is responsible for motor vehicle safety standards, and contracts with SAE to coordinate the assignment of manufacturer identifiers. Under 49 CFR S565.5(b), *Reporting Requirements*, a manufacturer or its agent must submit its unique identifier to SAE at least 60 days before using its identifier. Apparently, Nix Enterprises failed to follow proper procedures for obtaining the WMI Code designation. NHTSA considers this failure to be the kind of error that can have adverse safety consequences because it could impair both Omni's and Nix's ability to conduct recall campaigns. I shall refer this matter to the NHTSA Office of Enforcement for appropriate action.; Sincerely, Erika Z. Jones, Chief Counsel