Interpretation ID: 2835yy
Keller & Heckman
1150 17th Street, N.W.
Suite 1000
Washington, D. C. 20037
Dear Mr. Mounteer:
This responds to your letter on behalf of your client, Heritage Motors, that asked whether Heritage, given the nature of its manufacturing process, must assign its own Vehicle Identification Numbers (VINs). I apologize for the delay in this response. As discussed below, since Heritage considers the vehicles it manufactures to be: (l) "new" vehicles and (2) manufactured in one stage, it must assign its own VINs to the cars. I note that this letter addresses the vehicles Heritage assembles and not the "kits" which Heritage also sells.
According to your letter, Heritage Motors makes replica Mercedes 500K passenger cars, using 1970-1981 Chevrolet Camaros as donor cars. An information brochure accompanying your letter describes the parts that are removed from the Camaros and then reused in the Mercedes replica. Since Heritage uses a new body, engine, transmission, and many other new or remanufactured parts, you have considered the completed vehicle to be a "new" motor vehicle. Moreover, Heritage manufactures the vehicles in one stage.
Under section S4.l of Federal Motor Vehicle Safety Standard No. ll5, Vehicle Identification Number--Basic Requirements, each vehicle manufactured in one stage must have a VIN that is assigned by the manufacturer. Heritage must therefore assign its own VIN numbers to the cars it manufactures.
I hope this information is helpful. If you have any additional questions, please feel free to contact Ms. Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.
Sincerely,
Paul Jackson Rice Chief Counsel ref:115 d:2/l/9l