Interpretation ID: nht93-4.43

DATE: June 23, 1993

FROM: Howard Schecter

TO: Office of Cheif Counsal (Chief Counsel), NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8/16/93 from John Womack to Howard Schecter (A41; Std. 115)

TEXT:

I am seeking help in obtaining a guidance document regarding a 3 wheeled motorcycle that I purchased from a second party in California and then shipped to Hawaii.

The trike is made with a Corvair frame, engine, and transmission. The front end is a Yamaha. Hawaii has a Reconstructed Vehicle Department, which I brought the trike to for inspection. I was told the trike didn't have a 17 digit Federal ID#, therefore I couldn't register the trike.

I called the manufacture in California. He told me the following: when he first started building these trikes many years ago, he was approached by an inspector from the DMV. He was told that he had to apply for a manufacturers license. After filing the application it was returned to him by the same inspector telling him that California didn't consider him a manufacturer since he was using all used equipment was allowed to continue building his trikes. He was then told to take his trike to the California Highway Patrol to obtain a VIN#, an engine ID#, and a control number.

He was not told anything about Federal ID#. He has shipped his trikes all over the U.S. including 4 trikes to the Big Island of Hawaii. He manufactures about 6 trikes per year. I would appreciate whatever help you can lend me so that I can get my trike registered in this state.