Interpretation ID: nht94-7.49

DATE: March 9, 1994

FROM: J.L. Steffy -- Triumph Designs Ltd.

TO: Dave Elias -- Office of the Chief Counsel

TITLE: None

ATTACHMT: Attached to letter dated 3/29/94 from John Womack to J.L. Steffy (A42; Part 565)

TEXT:

I am writing to ask for an interpretation of CFR 565.4 with the possibility of gaining a waiver from NHTSA.

With respect to the VIN Label Table VI shows that a letter code is given for each MODEL YEAR. Currently our VIN labels have a letter code for the YEAR PRODUCED. Therefore, a 1994 model year vehicle could have letter code "P" for 1993 if it was produced in November 1993, for example. This assists us from a traceability standpoint. WE WOULD LIKE TO MAINTAIN OUR PRESENT SYSTEM IF AT ALL POSSIBLE. I believe we agree with the spirit of 565.4, which is to match a time frame to a letter code within the VIN.

As we are currently preparing all items for entry into the U.S. this fall, I would like to hear from you as soon as possible. I appreciate your assistance.