Interpretation ID: aiam2226
Assistant Vice President
National Association of Independent Insurers
2600 River Road
Des Plaines
Illinois 60018;
Dear Mr. Murphy: This is in response to your letter of February 17, 1976, in which yo asked that we reconsider our opinion of January 13 that any State laws regulating the content of vehicle identifications numbers (VIN's) would be preempted by Standard No. 115. Your reason was that the lack of standardization of VIN's caused many problems for insurance companies, State licensing agencies, and traffic enforcement agencies.; I think you might have misunderstood our intention concerning VIN's W agree that non-standardization of them is costly to all concerned, and we are working actively to promulgate a standardizing amendment to Standard 115. We are concerned, moreover, that if the States do not act in a uniform manner in laying down requirements for manufacturers, they might impose severe and unnecessary costs on them (and the public). This, of course, was the reason why Congress inserted the preemption provisions in the Vehicle Safety Act in the first place.; We want very much to have a system that applies not only to all State and all manufacturers, but to all the countries of the world, so that vehicles may move freely without danger of running afoul of identification standards. We have been working closely for several years with the International Standards Organization and the Society of Automotive Engineers to arrive at an acceptable world-wide uniform system. Our development work is finished now, and we expect to be issuing a proposal shortly for such a uniform system. We will appreciate your interest and your help in finalizing our standard in this area.; Sincerely. James B. Gregory, Administrator