Interpretation ID: nht79-1.20

DATE: 09/20/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Volvo of America Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

Norman Friberg, 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 your telephone conversations with Mr. Schwartz of my office.

Section 4.5.2 of Federal Motor Vehicle Safety Standard No. 115 (Vehicle 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 is the "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 version of the vehicle in its VIN.

Based on the facts presented, it is apparent that each "sales version" could also be designated a "series" if 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

February 5, 1979

Mr. Joseph J. Levin, Jr. Chief Counsel Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, SW Washington, DC 20590

Re: Request for Interpretation, FMVSS No. 115

Dear Mr. Levin:

Section 4.5.2 of FMVSS No. 115 states that the second section (Vehicle Attributes section) of the VIN shall consist of five characters which shall uniquely identify attributes which, for passenger cars, must include line, series, body type, engine type, gross vehicle weight rating and restraint system type. Section 3 defines "series" as a name which a manufacturer applies to a subdivision of a "line" denoting price, size or weight identification, and which is utilized by the manufacturer for marketing purposes.

Currently, Volvo markets only one line of passenger cars in the United States, the "200-series" which includes 2-door and 4-door sedans, 2-door coupe, and station wagon body types. Except for the differences dictated by body type, U.S. Volvo car models share the same chassis, suspension and, to a great degree, body components. In fact it can be said that, except for minor cosmetic differences, all Volvo cars of a given model year and body type are basically the same in structure and appearance.

These minor differences are denoted by a "sales version" suffix which is a two or three-letter designation. The sales version's currently available in the U.S. are DL, GL, GLE, and GT. (A further designation, C, is used to designate the coupe, which is actually a different body type.) The cosmetic differences denoted by sales version may include such items as:

Grille Emblem Wheel Design Electric Mirrors Leather Upholstery Front Spoiler Rectangular Headlamps Tachometer Fog Lamps The distinction between sales version is further diluted by the fact that most of the components listed are available as options, and many Volvo owners select these options so that their car more closely resembles a higher priced version.

In future model Volvos, the sales version may also designate engine type (number of cylinders, gasoline or diesel). However, this information is coded elsewhere in the Vehicle Attributes section of the VIN.

While sales version may have some slight impact on retail price, this is determined to a far greater extent by body type, engine type, and the options chosen by the purchaser.

It is our interpretation that sales version, as described above, must not necessarily be decipherable from the VIN. Please advise as to whether you agree with this interpretation.

If I can be of any assistance in this matter, please feel free to call.

Sincerely yours,

VOLVO OF AMERICA CORPORATION Product Planning and Development

Norman Friberg, P.E. Engineer, Regulatory Affairs

NF/EB