Interpretation ID: nht88-1.64

TYPE: INTERPRETATION-NHTSA

DATE: 03/07/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Robert L. Bernard

TITLE: FMVSS INTERPRETATION

TEXT:

Robert L. Bernard Attorney at Law 12342 Wrenthrope Drive Houston, TX 77031

Dear Mr. Bernard:

This letter responds to your inquiry of August 21, 1987, where you asked for this agency's opinion on whether Federal motor vehicle safety standard 115 (49 CFR S571.115) requires a manufacturer's chrome script name on the trunk of vehicles it manufacture s. It does not.

Standard 115, Vehicle Identification Number- Basic Requirements, directs a vehicle manufacturer to place a discrete vehicle identification number (VIN) on each vehicle it manufactures. Under paragraph S4.5, the VIN for any motor vehicle must appear indel ibly on a Dart of the vehicle other than the glazing, that is not designed to be removed except for repair. Paragraph S4.6 states that the VIN for passenger cars must appear inside the passenger compartment. Title 49 CFR Part 565, VIN-Content Requirement s, states that among other things, the VIN's first three characters must identify the vehicle manufacturer. However, neither Standard 115 or 565 require a manufacturer's name plate to appear on the vehicle.

I hope you find this information helpful.

Sincerely,

Erika Z. Jones Chief of Counsel

Erika Z. Jones Chief Counsel N.H.T.S.A. 400 7th Street, S.W. Washington, D.C. 20590 Re: FMVSS-115

I have purchased a AC Mark IV motor vehicle manufactured by Autokraft in England which complies with all D.O.T. and E.P.A. rules and regulations and is imported and sold through Ford Motor Company franchised dealers with Ford warranty.

Enclosed please find a copy from the company brochure.

I have requested the deletion of the chrome script name "Autokraft" from the trunk from the manufacturer.

I request your opinion that the above standard and regulation does not require the chrome script name "Autokraft" on the trunk because there is the name and data plate affixed to the body in the engine compartment.

I have discussed this matter with Joan Tilghman and she requested that I write to you.

Please advise.

Very truly yours,

Robert L. Bernard

RLB/kmr/ed

cc: Joan Tilghman