Interpretation ID: aiam2908
Palmer Machine Works
Old Round House Road
Amory
Mississippi
38821;
Dear Mr. Palmer: This is in response to your letter of November 10, 1978, concernin Federal Motor Vehicle Standard No. 115, *Vehicle identification number*, and in confirmation of your telephone conversation with Mr. Schwartz of my office.; Unfortunately, we do not have a simplified version of the standar which applies only to trailers. We have also modified the standard somewhat since the August 1978 version you referred to in your letter. I have attached a copy of the modification as well as a proposed further modification. I realize this is a complex standard, and, therefore, offer the following comments:; 1. Since you produce less than 500 vehicles per year, characters 1, 2 3, 11, 12 and 13 of the VIN will represent your manufacturer identifier. The date by which your manufacturer identifier must be submitted to the NHTSA has been changed to September 1, 1979. It is our understanding that the Society of Automotive Engineers will be willing to help you determine your manufacturer identifier. You should contact: Mr. Leo Ziegler, Society of Automotive Engineers, 400 Commonwealth Drive, Warrendale, Pennsylvania 15096, (412) 776-4841.; 2. The 4th, 5th, 6th, 7th and 8th characters of the VIN represen descriptive information about your vehicles. In the case of trailers, the type of trailer, series, body type, length and axle configuration must be represented. Since your model number can be associated with all these characteristics, you may want to incorporate it into the vehicle descriptor section.; 3. The 9th character of the VIN represents the model year of th vehicle, and should be determined from Table II which appears in the standard.; 4. The 10th character of the VIN represents the plant of manufacture Since your firm has only one plant, you may choose any character you desire except one specifically precluded by the standard.; 5. Since your firm manufacturers less than 500 vehicles each year, th last three characters of the VIN represent the number that is sequentially assigned to a vehicle in your production process.; 6. The check digit which immediately precedes the third character o the VIN is determined by the mathematical operation described in section S5 of the standard. Since most characters in your VIN will be standardized, the check digit should be fairly easy to determine.; Please contact me if you have any further questions. Any trad associations to which you belong should also be helpful in establishing your VIN procedures.; Sincerely, Joseph J. Levin, Jr., Chief Counsel