Interpretation ID: nht80-4.20

DATE: 11/07/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: International Harvester

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Stephen E. Mulligan International Harvester 4O1 North Michigan Avenue Chicago, IL 60611

Dear Mr. Mulligan:

This is in response to your letter of October 1, 1980, in which you ask whether compliance with 49 CFR 567, Certification, will satisfy the requirements of S4.3 of Federal Motor Vehicle Safety Standard No. 115, 49 CFR 571.115.

Section 4.3 of Federal Motor Vehicle Safety Standard No. 115 requires that the vehicle identification number (VIN) "appear clearly and indelibly upon either a part of the vehicle other than the glazing that is not designed to be removed except for repair or upon a separate plate or label which is permanently affixed to such a part." S4.3.1 requires each character to appear in a capital, sans serif typeface. In the case of passenger cars and trucks of 10,OOO pounds or less GVWR, each character must have a minimum height of 4 mm. s4.4 specifies that the VIN for passenger cars and trucks of 10,000 pounds or less GVWR shall be located within the passenger compartment.

Section 567.4 of Part 567, Certification (49 CFR 567), requires that the certification label be permanently affixed to the vehicle, and display the vehicle identification number. Consequently, for all vehicles except passenger cars and trucks of lO,OOO pounds or less GVWR, compliance with S 567.4 of Part 567 would also effect compliance with S4.3 of Standard No. 115 so long as capital, sans serif typeface was used.

Sincerely,

Frank Berndt Chief Counsel

October 1, 1980

Mr. Frank Berndt U.S. Department of Transportation Office of the Chief Counsel National Highway Traffic Safety Administration 400 7th Street, S.W. Washington DC 20590

Dear Mr. Berndt:

I am writing to request clarification of requirements which arise under Part 567 - Certification. S 567.4 requires each manufacturer of motor vehicles to affix to each vehicle a label which shall be permanently placed so that it cannot be removed without destroying or defacing it. The label is required to contain the vehicle identification number (VIN).

Federal Motor Vehicle Safety Standard No. 115 requires that each vehicle manufactured have a VIN which shall appear clearly and indelibly upon either a part of the vehicle or upon a separate plate or label permanently affixed to such a part.

International Harvester Company requests confirmation that compliance with the certification label requirements of Part 567 insures that there is also compliance with the VIN requirements set forth in FMVSS 115.

Thank you for your time and attention to this matter.

Very truly yours,

Stephen E. Mulligan

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