Interpretation ID: aiam4650
Norwich
Norfolk NR14 8EZ ENGLAND;
"Dear Mr. Gould: Thank you for your letter asking whether a worl manufacturer identifier (WMI) assigned by the Society of Automotive Engineers (SAE) pursuant to a contract with this agency may be deleted from SAE's register of assigned WMIs upon request of a foreign national governmental agency, but without the consent of the holder of the WMI. Absent some extraordinary circumstances, the answer to your question is no. 49 CFR Part 565, Vehicle Identification Number - Content Requirements, sets forth format and content requirements for vehicle identification numbers (VINs). Section 565.4(a) specifies that the first three characters of the VIN shall be the manufacturer's WMI, which is 'assigned in accordance with /565.5(c) of this part.' Section 565.5(c) specifies that the SAE assigns WMIs to vehicle manufacturers under contract with the National Highway Traffic Safety Administration (NHTSA). No provision in NHTSA's regulations sets forth any procedures for deleting assigned WMIs from the SAE register upon the request of any party, even the manufacturer assigned the WMI. Similarly, no provision in the contract specifically addresses the issue of deleting assigned WMIs for any reason. In its contract with NHTSA, SAE has agreed to 'furnish the facilities, materials, personnel and services necessary to accomplish the work...' We contacted the SAE's WMI Coordinator to learn how they have handled this situation in the past. We were informed that the WMIs are assigned by the SAE for an indefinite period with no express provision for revocation of the assignment. There have been a few isolated instances in which the party to whom a WMI was assigned has contacted SAE and asked that the WMI assignment be revoked. In those instances, the SAE has granted the manufacturer's request but the revoked WMI is never reassigned to another manufacturer. To date, SAE has never been asked to delete an assigned WMI by any party other than the manufacturer to whom the WMI was assigned. If a situation arose in which the SAE was asked to delete an assigned WMI without the knowledge and consent of the manufacturer to whom the WMI was assigned, the SAE assures us that they would not act on the request without consulting this agency. If and when we are ever consulted by SAE for our opinion on how to handle such a request, we would carefully consider the circumstances of the particular case before advising SAE on how to respond to the request. As a general matter, however, NHTSA does not favor the deletion of assigned WMIs for any reason. Sincerely, Stephen P. Wood Acting Chief Counsel";