Interpretation ID: aiam2911
Conco Inc.
Mendota
Illinois 61342;
Dear Mr. Schmidt: This is in response to your letter of October 27, 1978, concerning th application of Motor Vehicle Safety Standard No. 115 to final stage manufacturers and in confirmation of your telephone conversation with Mr. Schwartz of my office.; The National Highway Traffic Safety Administration has amended Standar No. 115 to shift the responsibility for assigning the vehicle identification number for vehicles manufactured in more than one stage from the final stage manufacturer to the incomplete vehicle manufacturer (copy enclosed). We appreciate your desire to comply fully with the standard but, with this recent amendment, compliance will not be required by final stage manufacturers.; In response to your question concerning the 'model year' to be used fo trailers, the calendar year is acceptable as the 'model year.' Should you have any other questions concerning your responsibility for assigning VINs to the trailers you manufacture, please do not hesitate to contact me.; Sincerely, Joseph J. Levin, Jr., Chief Counsel