Interpretation ID: nht79-4.34

DATE: 08/07/79

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mark Marks

TITLE: FMVSS INTERPRETATION

TEXT: In response to the request of Ms. Chris Anderson of your office, I have enclosed a copy of a letter which I recently wrote detailing the National Highway Traffic Safety Administration (NHTSA) regulations pertinent to the manufacture of trailers. Please note the reference on page 2 of the letter concerning the "Manufacturer Identification" requirements. These requirements are independent of those pertinent to the Vehicle Identification Number.

Under current regulations (49 CFR Part 571.115), manufacturers of trailers are not subject to the Vehicle Identification Number requirements. However, pursuant to recent amendments (see enclosed copy), a manufacturer of trailers will be required to affix a Vehicle Identification Number to every trailer manufactured on or after September 1, 1980. Although, the Vehicle Identification Number will not have to be affixed until this date, certain reports will be required in advance. Any trailer manufacturer who begins production before September 1, 1979, must report to NHTSA by that date the characters that he will include in his Vehicle Identification Numbers to uniquely identify himself, the make and the type of vehicle he produces. A manufacturer beginning production after September 1, 1979, must submit this information at least 60 days before he begins affixing the Vehicle Identification Numbers to vehicles.

I hope that this information will be helpful to you and your constituent. I will be happy to answer any further questions that you may have.

SINCERELY,

Attachment: See 8/31/79 letter from F. Berndt to Vesely Company.