Interpretation ID: 1931y
Levinson, Murray & Jensen, P.C.
Suite 400
312 West Randolph Street
Chicago, IL 60606
Dear Mr. Norton:
This is in reply to your letter with respect to compliance of imported motor vehicles with the Federal standard relating to vehicle identification numbers (VIN). I regret the delay in responding.
You have asked "in what manner does the importer affix the vehicle identification number to the tag that is to be located so as to be visible from the outside of the vehicle through the left portion of the windshield? Is the proper procedure to acertain the proper chassis number of the vehicle, and then to fashion, emboss, and affix a plate of any design that would comport with the visibility regulations," or is it affixed by the State authority that licenses the vehicle.
Compliance with any Federal motor vehicle safety standard is the responsibility of the importer of any vehicle not originally manufactured to comply with the standards. Compliance with Standard No. ll5 requires affixation of the VIN in the location you described (paragraph S4.6). The VIN label should be affixed by the person conforming the vehicle, as compliance with all Federal motor vehicle safety standards, including Standard No. ll5, must be demonstrated simultaneously in order to satisfy Federal requirements. A State does not affix VINs.
In response to a request you made for information, please note that we have searched our records and find no l98l or other model Mercedes-Benz with the serial number WDB10704612000486.
Sincerely,
Stephen P. Wood Acting Chief Counsel /ref:115 d:8/7/89