Interpretation ID: nht80-1.19

DATE: 02/29/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Suzuki Motor Co. Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of February 7, 1980, asking whether a partial vehicle identification number (VIN) may be stamped into the frame of the Suzuki motorcycles under the certification label.

The answer is yes. The use of identifying numbers other than the VIN is allowed if the numbers cannot be confused with the VIN. In the situation you described, the identifying number would be hidden from view by the certification label. Since the label is required to be riveted or permanently affixed to the vehicle (Part 567 of Title 49, Code of Federal Regulations), the hidden identifying number is not likely to become visible during the life of the vehicle. Therefore, there appears to be no chance that the number would be confused with the VIN.

Sincerely,

ATTACH.

February 7, 1980

Frank Berndt -- Chief Counsel, National Highway Traffic Safety Administration

Re: Request for Interpretation FMVSS No. 115 - Vehicle Identification Number

Dear Mr. Berndt:

This is to request an interpretation by your Agency regarding Section S4.3 of the Standard.

Suzuki as required by Part - 567 Certification (@ 567.4(g)(6) ) will place the Vehicle Identification Number on the Motorcycle Certification Label.

Suzuki wishes to also stamp, using 5mm Sans Serif characters, the Vehicle Identification Number minus the check digit onto the headpipe of the motorcycle (at the intersection of the steering post with the handlebars). This second placement of the Vehicle Identification Number would be for internal use by the Company prior to the Certification label being affixed on the headpipe of the motorcycle.

This second placement of the Vehicle Identification Number would be entirely covered by the Certification label when it is affixed to the motorcycle.

We wish to obtain your interpretation if such a plan would be permissible under the standard, by not including the check digit in the second application of the Vehicle Identification number, whereas it would not be visible to either the consumer or Law Enforcement Personnel unless the label had been removed from a motorcycle. We believe that this number, even though it was missing the check digit, would be helpful in identifying such a motorcycle.

We would appreciate being advised of your opinion at the earliest possible date regarding this request.

Sincerely,

SUZUKI MOTOR CO., LTD.;

F. Michael Petler -- Manager, Government Relations Department