Interpretation ID: nht91-4.6

DATE: May 28, 1991

FROM: Roddy Williams -- Container Enterprise

TO: Paul J. Rice -- Chief Counsel, NHTSA

TITLE: Reference: FMVSS No. 115 Vehicle Identification

ATTACHMT: Attached to letter dated 7-12-91 from Paul Jackson Rice to Roddy Williams (A38; Std. 115; Part 571.7(f); VSA 108(a)(2)(A))

TEXT:

Container Enterprise is a chassis manufacturer in New Orleans, La. and is registered with S.A.E. to apply VIN numbers. We are presently converting container chassis from their original 23' length to a new length of 27' which will enable them to conform to the new Federal Bridge Formula.

Leasing companies have contracted us to modify these older chassis carrying a five digit VIN number. According to S.A.E., current regulations require a seventeen digit VIN number on any new and remanufactured productions. Any length change would also constitute a VIN number change.

Explanation of Modification:

The original chassis is 23' long. We remove the axles and half of the cross members on the original frame. We manufacture a 12' subframe and reinstall axles to the subframe. The subframe upon completion will extend the chassis length to 27'. The conversion will allow the chassis to slide open or closed.

Upon completion of modification, Container Enterprise will issue a new manufacturer plate with a new VIN number and date of remanufacture. A remanufacture certificate of orgin is sent to the leasing company and the leasing company registers the chassis.

It is our understanding after a telephone conversation with D. Nacoma with N.H.T.S.A. that the original manufacturer is no longer responsible after remanufacturing is completed. It is also our understanding that the remanufacturer assumes responsibility of the chassis meeting all of N.H.T.S.A. standards.

According to the Department of the Treasury Publication 510, Excise Taxes, Page 10, Heavy Trucks, Trailers, & Tractor: F.E.T. is not taxable on remanufactured equipment.

We feel that these procedures comply with all requirements and regulations. We would appreciate your review of these procedures and responding with any comments or opinions.

Should you require additional information or clarification, please contact me at your convenience.