Interpretation ID: 17570.drn

Mr. Mark Recchia
Liaison Engineer
Fiat Auto R & D U.S.A.
39300 Country Club Drive
Farmington Hills, MI 48331-3473

Dear Mr. Recchia:

This responds to your March 18, 1998, request for an interpretation whether a vehicle identification number (VIN) placed inside a motor vehicle passenger compartment may be divided into two lines. You explain that Maserati "uses this practice in Europe because of space restrictions, and its acceptance in the United States would facilitate the production of U.S.- version Maserati cars." Assuming the VIN meets all other requirements of 49 CFR Part 565 Vehicle Identification Number Requirements, the answer is yes.

In Part 565, the National Highway Traffic Safety Administration (NHTSA) specifies the format, content, and physical requirements for a VIN system and its installation. General requirements for a VIN system are specified at Section 565.4 General requirements. Although NHTSA is aware only of VINs written in one line, nothing in Section 565.4(f) prohibits a VIN from being written in two lines. Since there is no prohibition against it, Maserati may write the passenger compartment VIN in two lines.

I note that in the example of the VIN you have provided, the first line of the VIN is preceded by a star, followed by the first nine digits of the VIN, then another star. The second line of the VIN begins with a star, followed by the last eight digits of the VIN, then another star. These stars would be considered "dividers" in the VIN. In a letter of November 20, 1978, to Volkswagen of America, Inc. (copy provided), NHTSA stated the following about VIN dividers:

'[d]ividers' which would appear at the 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 nor numeric characters which might be mistaken for part of the VIN.

As stated in the letter to Volkswagen, Fiat and Maserati must ensure that any VIN dividers not be in alphabetic or numeric characters which might be mistaken for part of the VIN.

You state that the attached diagram is "from a European application." We cannot determine from your letter whether the VIN location in the diagram meets 49 CFR 565.4(f) which states that the VIN shall be readable "through the vehicle glazing under daylight lighting conditions by an observer having 20/20 vision (Snelling) whose eye-point is located outside the vehicle adjacent to the left windshield pillar." Before being sold in the U.S., the VIN on the passenger car must meet this and all other requirements specified in Part 565.

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

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
d.7/15/98
ref:565