Interpretation ID: 86-5.17

TYPE: INTERPRETATION-NHTSA

DATE: 09/12/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Davis Thekkanath

TITLE: FMVSS INTERPRETATION

TEXT:

SEP 12 86

Mr. Davis Thekkanath Oshkosh Truck Corporation P.O. Box 2566 2307 Oregon St. Oshkosh, WI 54903-2564

Dear Mr. Thekkanath:

This responds to your letter dated May 9, 1984, regarding the placement of the vehicle identification number (VIN) on heavy duty vehicles. You asked whether a heavy duty truck must have a VIN that meets the location requirement of S4.6 of the standard or whether the VIN for such a vehicle can be located on the vehicle certification plate. As discussed below, the VIN for a truck with a gross vehicle weight ratings (GVWR) of 10,000 pounds or more can be located on the vehicle certification plate.

Standard No. 115. Vehicle Identification Number - Basic Requirements, requires passenger cars, multipurpose passenger vehicles, trucks, buses, trailers, incomplete vehicles, and motorcycles to have a VIN. S4.5 of the standard requires the VIN to appear indelibly on a part of the vehicle which is not designed to be removed except for repair or upon a separate plate which is permanently affixed to the vehicle. S4.6 of the standard specifies the location of the VIN inside the passenger compartment for passenger cars, multipurpose passenger vehicles, and trucks of 10,000 pounds or less GVWR. However, the VIN location requirement of S4.6 does not apply to vehicles with a GVWR over 10,000 pounds.

As you correctly noted, Part 567, Certification, requires the VIN to be located on the certification label of motor vehicles. Since S567.4(b) requires the certification label to be permanently affixed to the vehicle, the agency considers providing the VIN in this location as complying with the requirement of S4.5 of Standard No. 115.

I hope this information is helpful to you.

Sincerely,

Erika Z. Jones Chief Counsel

May 9, 1986

Office of Chief Counsel National Highway Traffic Safety Administration 400 7th St. S.W. Washington. D.C. 20590

Subject: Placement of Vehicle Identification Number

Gentlemen:

We are manufacturers of heavy duty vehicles of GVWR of over 10,000 lbs. In our effort to find the exact federal requirement of the placement of the vehicle identification number, we scanned through FMVSS 115 for an answer. It specifically addresses in paragraph 4.6. vehicles of GVWR 10,000 lbs or less. Does this requirement apply for us also?

We currently have the certification label of which "VIN" is a part, placed inside the cab per 49 CFR 567 paragraph 4. Does this satisfy the "VIN" placement requirement? Does the regulation require that "VIN" be placed on any other part of the vehicle in addition to that on the certification label placed inside the cab?

We would appreciate your responding in writing to us as soon as possible.

Sincerely, OSHKOSH TRUCK CORPORATION

Davis Thekkanath Sr. Supervising Engineer

DT:ks