Interpretation ID: aiam4152
Esqs.
Donovan Leisure Newton & Irvine
333 South Grand Avenue
Los Angeles
CA 90071;
Dear Messrs. Waimey and Hansell: This responds to your letter asking two questions about Part 541 *Federal Motor Vehicle Theft Prevention Standard*. First, you asked if the 17-character vehicle identification number (VIN) required on original equipment engines and transmissions had to appear in a single line. You stated that your client would like to mark the engines and transmissions by splitting the VIN into two groups, with the second group of characters directly below the first. Such markings would comply with Part 541. Second, you asked if your client could use a trademark that was less than one centimeter high for marking replacement parts. Markings less than one centimeter high would not comply with the requirements of Part 541 applicable to replacement parts. These conclusions are explained in detail below.; If a vehicle manufacturer was not identifying its engines and/o transmissions with at least an 8- character VIN derivative as of October 24, 1984, S541.5(b)(1) requires the engine and transmission to be marked with the full 17-character VIN. That section does *not* require that the 17 characters appear on the same line. However, the preamble to the final rule establishing Part 541 explained the policy reasons for requiring the full 17-character VIN as follows:; <<