Interpretation ID: aiam2885
Jr.
Washington Representative
Volkswagen of America
Inc.
475 L'Enfant Plaza S.W.
Washington
D.C. 20024;
Dear Mr. Hutchinson: Thank you for your letter of September 8, 1978, concerning Federa Motor Vehicle Safety Standard No. 115, *Vehicle identification number*. Since the agency was considering petitions for reconsideration when your letter was received, we concluded that it would be more helpful to respond to your letter after the revised standard was issued. A copy of the amendments to the standard and a copy of a notice of proposed rulemaking to amend the standard are enclosed.; In confirmation of your meeting with Messrs. Carson, Erikson, an Schwartz, you are correct in stating that vehicle description section (VDS) informational content can change from model year, to model year even though the actual characters in the VDS remain the same. All changes in the informational content of the VDS must, of course, be submitted to the NHTSA as required in S6 of the standard.; As you point out in your letter, 'dividers' which would appear at th beginning and the end of the VIN would not be considered part of the VIN and, therefore, would not be regulated by the standard. Care should be taken, however, to ensure that the dividers are neither alphabetic not numeric characters which might be mistaken for part of the VIN.; In your meeting with NHTSA staff, you requested clarificatio concerning which manufacturer identifier should be used when the vehicle assembly is carried out by one company on behalf of another. In this instance, the manufacturer identifier of the company under whose authority the assembly is carried out and which maintains responsibility for the vehicle's compliance with safety standards should be used. You have also asked for a definition of the term 'transfer document.' A 'transfer document' will vary in content from manufacturer to manufacturer, but means the document(s) given to the owner of the vehicle for use when the vehicle is being titled.; We would also call to your attention proposed changes to the standar contained in the enclosed notice of proposed rulemaking. If the proposed changes are adopted, the check digit would be placed in the fourth position of the VIN, and the first and second characters of the VDS, which immediately follow the check digit, would be alphabetic.; Sincerely, Joseph J. Levin, Jr., Chief Counsel