Interpretation ID: nht80-3.43

DATE: 08/29/80

FROM: AUTHOR UNAVAILABLE; Stephen P. Wood; NHTSA

TO: Columbia Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 17, 1980, and in confirmation of your several telephone conversations with Mr. Schwartz of my office.

In your letter, you asked whether the vehicle identification number (VIN) required by Federal Motor Vehicle Safety Standard No. 115 (49 CFR 571.115) must reflect each of your 16 moped "models" if the differences between the models are cosmetic. Table 1 of S4.5.2 requires that the following information be encoded in the VIN of motorcycles: Type of motorcycle, line, engine type, and net brake horsepower. The encoding of models is not required. "Line" is defined in S3. Definitions to mean a name which a manufacturer applies to a family of vehicles within a make which have a degree of commonality in construction, such as body, chassis or cab type. Therefore, if the 16 moped "models" are of the same construction, they would not be considered different lines unless Columbia chose to designate them as different lines.

You have also stated that Columbia has changed its moped motor manufacturer and has made minor modifications in its open frame moped. You wish to know if this must be reflected in the VIN. The VIN standard for mopeds does not take effect until September 1, 1980, for vehicles whose model year changeover date occurs prior to September 1, 1980, and subsequent to January 1, 1981, and until the actual model year changeover date for vehicles whose model year changeover date falls between these two dates. Therefore, any changes Columbia has made prior to the effective date of the standard would presumably already be reflected in the VIN.

The National Highway Traffic Safety Administration does not give advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed labels as forwarded with your letter. Based on our understanding of the information which you have provided, your labeling system apparently complies with Standard No. 115.

Sincerely,

ATTACH.

June 17, 1980

Fred Schwartz -- Department of Transportation, N.H.T.S.A.

Dear Mr. Schwartz,

We have 16 moped models. Most of these models are different cosmetically. Is it necessary to have these models reflect in our V.I.N. number?

We also changed our motor manufacturer and have minor changes in our open frame moped. Is it also necessary for this to reflect in our V.I.N. number?

I would appreciate your approval on our enclosed sample and your answers to the above questions by June 27, 1980.

Sincerely,

David R. Stevens -- Quality Control Manager

enc.

1CEMT0156AC000001 1CEMT0158AC000002 1CEMT015XAC000003 JULY 1980 JULY 1980 JULY 1980 1CEMT0151AC000004 1CEMT0153AC000005 1CEMT0155AC000006 JULY 1980 JULY 1980 JULY 1980 1CEMT0(Illeg.)0000007 1CEMT0159AC000008 1CEMT0150AC000009 JULY 1980 JULY 1980 JULY 1980 1CEMT0157AC0000010 1CEMT0159AC000011 1CEMT0150AC000012 JULY 1980 JULY 1980 JULY 1980 1CEMT0152AC000013 1CEMT0154AC000014 1CEMT0156AC000015 JULY 1980 JULY 1980 JULY 1980 1CEMT0158AC000016 1CEMT015XAC000017 1CEMT0151AC000018 JULY 1980 JULY 1980 JULY 1980 1CEMT0153AC000019 1CEMT015XAC000020 1CEMT0151AC000021 JULY 1980 JULY 1980 JULY 1980 1CEMT0153AC000022 1CEMT0155AC000023 1CEMT0157AC000024 JULY 1980 JULY 1980 JULY 1980 1CEMT0159AC000025 1CEMT0150AC000026 1CEMT0152AC000027 JULY 1980 JULY 1980 JULY 1980 1CEMT0154AC000028 1CEMT0156AC000029 1CEMT0152AC000030 JULY 1980 JULY 1980 JULY 1980 1CEMT0154AC000031 1CEMT0156AC000032 1CEMT0158AC000033

MANUFACTURED BY COLUMBIA MFG. CO.

MOTOR DRIVEN CYCLE VEHICLE IDENTIFICATION NUMBER:

MANUFACTURED BY COLUMBIA MFG. CO.:

MOTOR DRIVEN CYCLE VEHICLE IDENTIFICATION NUMBER:

MANUFACTURED BY COLUMBIA MFG. CO.:

MOTOR DRIVEN CYCLE VEHICLE IDENTIFICATION NUMBER:

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