Interpretation ID: nht93-2.46

DATE: April 7, 1993

FROM: Donald W. Vierimaa -- Vice President, Engineering, Truck Trailer Manufacturers Association

TO: Dorothy Nakama -- Office of Chief Counsel, NHTSA

TITLE: Subject: Vehicle Identification Number (VIN)

ATTACHMT: Attached to letter dated 6-29-93 from John Womack to Donald W. Vierimaa (A41; Std. 115; Part 567).

TEXT: Section 4.6 of TTMA's Recommended Practice Number 56-91, "Trailer Vehicle Identification Number," states the following:

4.6 Rebuilt Trailers

If a rebuilt trailer meets the requirements of 49 CFR 571.7(f) as being newly manufactured, the rebuilder must furnish a new VIN. If the rebuilt trailer is considered not new by this requirement, the VIN of the original trailer shall be used in the legal paperwork, but there is no legal requirement to physically retain the VIN on the trailer.

A person has questioned whether the statement that "there is no legal requirement to physically retain the VIN on the trailer" is correct. Please inform us as to whether this statement is correct. It is my understanding that an owner of a motor vehicle is not prohibited from removing a VIN label from his motor vehicle.