Interpretation ID: aiam3204
Kawasaki Motors Corp.
USA
3630 Garry Avenue
P.O. Box 11447
Santa Ana
California 92711;
Dear Mr. Hagie: This is in response to your letter of January 24, 1980, to Mr. Schwart of my office requesting an interpretation of Federal Motor Vehicle Safety Standard No. 115.; I understand from your letter that Kawasaki Motors Corp., USA, intend to comply with S4.3 of Safety Standard No. 115 by placing the vehicle identification number (VIN) on the certification label of the motorcycles it manufacturers. Since the standard specifies the precise placement of the VIN only for passenger cars and trucks with a GVWR of 10,000 pounds or less (S4.4), placing the VIN on the certification label of motorcycles is authorized.; You also wish to know whether Standard No. 115 precludes Kawasak stamping a model designation and production sequence into the frame near the certification label. As long as the number which you stamp into the frame cannot be mistaken for the VIN because of its length or other factors, this would not be prohibited.; Sincerely, Frank Berndt, Chief Counsel