Interpretation ID: aiam3096
P.E.
Engineer
Regulatory Affairs
Volvo of America Corporation
Rockleigh
New Jersey 07647;
Dear Mr. Friberg: This is in response to your letter of February 5, 1979, and you telephone conversations with Mr. Schwartz of my office.; Section 4.5.2 of Federal Motor Vehicle Safety Standard No. 115 (Vehicl Identification Number) states that the second section of the vehicle identification number for passenger cars shall be decipherable into the vehicle's line, series, body type, engine type, and restraint system type. 'Line' is defined as 'a name which a manufacturer applies to a family of vehicles which have a degree of commonality in construction, such as body, chassis or cab type.' 'Series' is defined as 'a name which a manufacturer applies to a subdivision of 'line,' denoting price, size, or weight identification, and which is utilized by the manufacturer for marketing purposes.'; In Volvo's view, the only 'line' it markets in the United States in th '200-series.' Within this line, there are several models differentiated by body style and number of engine cylinders. Each model is offered in several different 'sales versions,' designated by a two- or three-letter suffix. Sales versions differ as to trim, upholstery, and other items which Volvo has designated as cosmetic. It is Volvo's desire not to encode the particular sales versions of the vehicle in its VIN.; Based on the facts presented, it is apparent that each 'sales version could also be designated a 'series' of Volvo desired. Nonetheless, the definition of 'series' makes clear that the responsibility for applying and utilizing the 'series' designation rests initially with the manufacturer. If a manufacturer chooses not to designate separate series for marketing reasons because of the superficiality of the differences between the potential series, the agency will not require such a designation.; Sincerely, Frank Berndt, Chief Counsel