Interpretation ID: 2634o

Lawrence C. Bourbeau, Jr., Esq.
Assistant General Counsel
Fruehauf Corporation, Law Department
10900 Harper Avenue
P.O. Box 238
Detroit, MI 48232

Dear Mr. Bourbeau:

This letter responds to your earlier inquiry where you ask whether NHTSA would object to your Company's changing "its model year designation from September 1 to July 1." I apoligize for the delay in responding.

Standard 115, Vehicle Identification Number- Basic Requirements, directs vehicle manufacturers to place a discrete identifying number (VIN) on each vehicle. Title 49 CFR Part 565, VIN- Content Requirements, states that a VIN must include a character indicating the manufacturer's designated model year. Neither Standard 115 nor Part 565 prohibits your company from changing the model year in the manner you suggest. Therefore, such a change does not violate our regulations.

We note that this change apparently concerns model year as a marketing concept. The Federal Trade Commission has published guidelines concerning model year as a commercial concept, and you may wish to contact the Commission for whatever assistance it may provide. I hope you find this information helpful.

Sincerely,

Erika Z. Jones Chief Counsel

ref:115 d:12/22/87