Interpretation ID: 2836o
Attorney at Law
12342 Wrenthrope Drive
Houston, TX 77031
Dear Mr. Bernard:
This letter responds to your inquiry of August 21, 1987, where you asked for this agency's opinion on whether Federal motor vehicle safety standard 115 (49 CFR 571.115) requires a manufacturer's chrome script name on the trunk of vehicles it manufactures. It does not.
Standard 115, Vehicle Identification Number- Basic Requirements, directs a vehicle manufacturer to place a discrete vehicle identification number (VIN) on each vehicle it manufactures. Under paragraph S4.5, the VIN for any motor vehicle must appear indelibly on a part of the vehicle other than the glazing, that is not designed to be removed except for repair. Paragraph S4.6 states that the VIN for passenger cars must appear inside the passenger compartment. Title 49 CFR Part 565, VIN-Content Requirements, states that among other things, the VIN's first three characters must identify the vehicle manufacturer. However, neither Standard 115 nor Part 565 require a manufacturer's name plate to appear on the vehicle.
I hope you find this information helpful.
Sincerely,
Erika Z. Jones Chief Counsel
ref:115#115 d:3/7/88