Interpretation ID: aiam3373
Toyo Kogyo USA Office
23777 Greenfield Road
Suite 462
Southfield
Mi 48075;
Dear Mr. Kawaguchi: This is in response to your letter of October 20, 1980, concernin Federal Motor Vehicle Safety Standard No.l 115, Vehicle identification number (49 CFR 571.115).; Your question concerns the submission of horsepower data to the agenc as required by the standard (S4.5.2). On February 25, 1980, the agency published an amendment to Standard No. 115 in the Federal Register (45 FR 12255) which authorized slight variations between the engine horsepower encoded in the vehicle identification number (VIN) and the actual engine horsepower. Except in the case of motorcycles, a variance in horsepower of plus or minus 10 percent was authorized. You wish to know whether the engine horsepower data you submit to the agency should be consistent with the VIN coding, or whether you should submit the precise horsepower.; The information which must be submitted pursuant to S6.3 is tha necessary to decipher the characters contained in the VIN. Consequently, the engine horsepower submitted should represent the horsepower actually encoded in the VIN, whether or not this is the precise horsepower.; Sincerely, Frank Berndt, Chief Counsel