Interpretation ID: nht94-7.15

DATE: March 29, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: J.L. Steffy -- Triumph Designs Ltd. (England)

TITLE: None

ATTACHMT: Attached to fax dated 3/9/94 from J.L. Steffy to Dave Elias (OCC 9753)

TEXT:

This responds to your request for an interpretation of model year designations specified in 49 CFR part 565 Vehicle Identification Number - Content Requirements. You asked whether the vehicle identification number (VIN) for a 1994 model year vehicle may use the symbol "P" to designate model year. The answer is no.

You stated that Triumph wishes to use, in its VIN, a letter code designating the year of vehicle manufacture. Triumph marks the letter "P" in the VIN of a vehicle manufactured in November 1993. Triumph considers this a MY 1994 vehicle.

The format for VIN content information is specified in part 565. Table VI of part 565 specifies that MY 1993 is designated by the letter "P" and MY 1994 is designated by the letter "R." Designating a MY 1994 vehicle with the letter "P," as you wish to do, could engender confusion since it would represent that the vehicle is a MY 1993 vehicle. Such confusion could hinder the accuracy and efficiency of vehicle recall campaigns.

You also asked if Triumph may be permitted a modification of the part 565 model year designations and designate its MY 1994 vehicles as "P." The answer is no. NHTSA has no procedures to permit manufacturers to modify or waive any of part 565.

We note that Triumph could use the letter "P" to designate the vehicle as a 1993 MY vehicle. Section 565.3(h) defines "model year" as:

the year used to designate a discrete vehicle model irrespective of the calendar year in which the vehicle was actually produced, so long as the actual period is less than two calendar years.

Assuming the actual production period of the vehicle is less than two calendar years, a vehicle manufactured in November 1993 could be a MY 1993 vehicle, identified by the letter "P."

I hope this information is helpful. If you have any questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992.