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Daimler's suggestion that the manufacturer have the option of choosing which character in the second section of the VIN to change from alphabetic to numeric or vice versa, would be even more confusing to VIN users. Under the approach suggested by Daimler and BMW, VIN users would be unable to use the seventh VIN character to determine the model year of makes and models of vehicles manufactured in both the 30 year span of the current VIN system and in the 30 year span contemplated for the VIN system established by today's final rule.

The agency is therefore adopting the proposal in the NPRM to require that only an alphabetic character be allowed in VIN position 7 for passenger cars and multipurpose passenger vehicles and trucks with a gross vehicle weight rating of kg.

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The agency agrees with the Alliance, GM and Prevost that a footnote to Table VII will further clarify the purpose of position 7 being an alphabetic character. The agency is therefore adding a footnote to Table VII, but is adopting language different from that proposed by the Alliance and GM to both further clarify the role of VIN position 7 and to make clear, as suggested by Prevost, that the requirement for an alphabetic character in position 7 applies only to passenger cars and multipurpose passenger vehicles and trucks with a gross vehicle weight rating of kg 10, lb or less.

A VIN will contain either a number or an X. A PIN will contain a letter and never an X. NHTSA has authority to regulate only vehicles that are manufactured primarily for use on public streets, roads, and highways. Consumer Product Safety Commission, which at this time does not have a system in place to provide identifiers for off-road vehicles. As indicated by the NYDMV, a voluntary system has been created and is operating to address the need for identifiers for off-road vehicles.

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It therefore did not address the issue in the NPRM and is not making this suggested change in this final rule. We do not regulate PINs. This is because a VIN is required to have either a numeric character or an X in that position. NATM, which represents companies that manufacture trailers with gross vehicle weight ratings GVWR of 26, lb or less, submitted detailed comments addressing issues unique to trailer manufacturers. NATM generally supported the proposed changes to Part , but raised the following two concerns.

By its silence, we assume Section These are the characters that may be used in a VIN unless there are specifications elsewhere in Part as to the characters that may be used in a particular VIN position. The specifications in the current version of this section as to the type of characters that must appear in specific positions of the second section of the VIN apply only to the vehicles cited—passenger cars and multipurpose passenger vehicles and trucks with a gross vehicle weight rating of kg 10, lb or less—not larger trucks, buses, trailers, and motorcycles.

Therefore, the current regulation allows manufacturers of larger trucks, buses, trailers, and motorcycles to use either an alphabetic or a numeric character in all four of the first four positions in the second section of the VIN, positions 4, 5, 6, and 7. Position 8 under the current regulation may be either an alphabetic or numeric character for any type of vehicle.

Nothing will change for these vehicles under this final rule. In this final rule, only position 7 will be limited to an alphabetic character for passenger cars, multipurpose passenger vehicles and trucks with a gross vehicle weight rating of kg 10, lb or less. All other positions in the second section of the VIN will be allowed to have either alphabetic or numeric characters no matter what type of vehicle is involved and position 7 may be alphabetic or numeric for larger trucks, buses, trailers, and motorcycles.

The NATM further stated that under the current regulation, the company name in the manufacturer identifier is, in essence, the make of the trailer. In most cases, only the manufacturer's name has been communicated in the manufacturer identifier of trailer manufacturers under the current Part It seems clear from the NATM comments that generating VINs for trailers is relatively straightforward in comparison to doing so for other types of vehicles subject to Part The NATM comments suggest that trailer manufacturers fear that if they are required to communicate a vehicle's make in the second section of the VIN, even though the manufacturer name is the make for most trailer manufacturers, they will have to use the position now widely used for GVWR to indicate the manufacturer's name for a second time the manufacturer's name will continue to be required in the manufacturer identifier.


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The agency notes that one option available to trailer manufacturers whose manufacturer name is the same as the make is to continue to use a character in the position that is now, by practice, used for GVWR. It should be noted that if a trailer manufacturer produces 33 or fewer variations of trailers i.

In fact, a trailer manufacturer could communicate up to different variations in the trailers it manufactures and use only four of the five positions in the VIN's second section by taking full advantage of the 33 characters available for each of those positions and submitting to NHTSA a full and complete description of what a given character means if it appears in a given position. The NATM comments made the agency aware of the fact that there is no current need to include low speed vehicles LSVs in the vehicles that must use an alphabetic character in position number 7 of the VIN as required by today's final rule.

These vehicles will now be treated the same as larger trucks, buses, trailers, and motorcycles. The classification system in Table II of Part has been in existence for nearly 30 years and a great deal of data has accumulated in various places based on this system. The agency's experience with this classification system suggests that the change advocated by NESCAUM could have a significant effect on the various data systems that are built on this system.

Any change to this system would require a complete and thorough analysis of the possible impact of that change on these data systems. This was not an issue addressed in the petition that initiated this rulemaking or in the NPRM. The agency is not acting on this recommendation at this time, not because the recommendation is deemed to lack merit, but instead because of the need to publish this final rule promptly. Manufacturers will be able to continue to use the WMIs they are currently using in production or that have been assigned to them. The agency does not see a need to take any action at this time beyond adopting the changes discussed in this final rule.

As previously noted, vehicle make has been moved from the manufacturer identifier to the second section of the VIN. This should substantially reduce the need to issue new large manufacturer WMIs, thus extending the remaining supply of of these manufacturer identifiers.

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In addition, the agency, through its contract with SAE for the issuance of manufacturer identifiers, has begun the process of identifying companies with large manufacturer identifiers that are no longer in business so that those Start Printed Page identifiers may be returned to the system. The agency is also identifying companies that were issued large manufacturer identifiers that, through publicly available data, the agency knows do not produce more than vehicles a year, the current threshold for being considered a large manufacturer, or 1, vehicles a year, the threshold in this final rule, under Part The agency anticipates that a number of large manufacturer identifiers will be returned to the system as a result of this process as well.

The agency is neither encouraging nor discouraging the use of this typeface. The agency has not changed its position with regards to this interpretation. NYDEC said it is unclear if vehicle make would become more difficult to obtain if the agency's proposal is finalized as written.

If moving the vehicle make from the first to the second section of the VIN has an impact on State regulatory programs, the AAMVA would presumably have discussed that matter with the committee. The agency does not believe that moving vehicle make from the first to the second section of the VIN will have any impact on the availability of this information to state programs.

The agency is therefore taking no action today in response to this comment.

Vehicle Identification Number Requirements

Harold R. We do not believe that it is necessary to adopt the use of symbols at this time. The changes proposed in the petition and those adopted in this final rule provide a sufficient number of unique VINs to assure the continued existence of the current VIN system, with the use of only numeric and alphabetic characters, for at least 30 additional years.

Section The agency is not aware of driver facing VIN plates creating unworkable difficulties in any broad category of other situations. As such, the agency is not specifying the direction in which the VIN plate must face in this rule. Because there are so few manufacturers in this category and the market is relatively small, a manufacturer, at least under the current Part with its vehicle dividing line between small and large manufacturers, may one year be a small manufacturer and the next a large manufacturer.

As a small manufacturer under current Part , it is required to use a six character manufacturer identifier. As a large manufacturer, it is required to use a three character manufacturer identifier. Prevost recently became a large manufacturer under the current Part and is concerned that it might have to return to using a small manufacturer identifier and change its whole VIN structure. It urged that the dividing line between low-volume manufacturers and high-volume manufacturers be set at a threshold lower than the current vehicles for manufacturers of vehicles greater than kg GVWR.

Prevost is principally concerned that it have one consistent approach to VINs and not have to switch between low-volume manufacturer VINs and high-volume manufacturer VINs.

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However, the agency believes that if we lower the threshold between low-volume manufacturers and high-volume manufacturers, such an action would jeopardize the limited supply of manufacturer identifiers for high-volume manufacturers, which was one of the driving concerns for the petition that initiated this rulemaking and for the agency's proceeding with this rulemaking. If, after the implementation of this final rule, there continue to be manufacturers that vacillate between low-volume and high-volume status, the best place to address this will be in the administration of the VIN system.

In this way, NHTSA can better monitor the supply of large manufacturer identifiers and be sure that they are issued only in situations where it is appropriate to do so. There were numerous comments concerning the effective date of the final Start Printed Page rule, particularly the need for the final rule to be implemented quickly with a clear indication that it applies to all model year vehicles. One commenter said the revised Part should apply to model year vehicles regardless of when they are manufactured.

TMA also urged quick adoption. NICB provided detailed comments that focused entirely on the issue of effective date. If the agency allows the VIN to become anything other than a truly unique identifier, it will cripple enforcement of the Anti-Car Theft Act, the Motor Vehicle Safety Act, the Imported Vehicle Safety Compliance Act and a host of other Congressional mandates to protect Americans from car theft, salvage fraud and death or injury on the nation's highways.

It would also jeopardize counter-terrorism efforts, especially the investigation of car bombings. NICB's Shipping and Assembly File, which includes nearly all motor vehicles produced for sale in the United States, typically receives from manufacturers some pre-production VIN assignments before the end of the calendar year that is two years before the model year. The company noted that under a U.

The effective date of this final rule is two-fold. It becomes mandatory in one year. That is, all vehicles manufactured on or after the date one year from today must have VINs that meet the requirements of this final rule. The effective date will be different for different manufacturers and different vehicles manufactured by the same manufacturer because of the different times those vehicles are manufactured within the same model year.

Under the current Part , a chart indicates the numbers and letters that are required in the 10th position for particular model year vehicles. These new requirements will both avoid duplicate VINs and enable a VIN user to distinguish the 30 year period in which a vehicle was manufactured.

NHTSA very much appreciates the concerns expressed over the need for the timely publication of this final rule. We believe the effective date of the rule gives regulated parties ample time to make the changes necessary to comply with the revised requirements of Part The current VIN requirements need to be retained for an interim period during the changeover to the new VIN requirements, for the benefit of any manufacturer that might be using the current Part VIN regulation.

This rulemaking document was not reviewed by the Office of Management and Budget under E. It is not considered to be significant under E. This document changes the VIN requirements that for the most part provide manufacturers greater flexibility in meeting VIN requirements:. This rule does not substantially change those requirements.

The minimal impacts of today's amendments do not warrant preparation of a regulatory evaluation. NHTSA cannot quantify direct safety impacts of this rule. However, NHTSA believes that this rule will have a beneficial effect on safety in that it ensures the continued integrity of the VIN system ensuring that vehicles will continue to be uniquely identified.

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There may be some cost impacts in changing data systems to account for features of the VIN that are different than those of current VINs e. In fact, manufacturers of most vehicles less than 10, lb GVWR will need to do nothing more initially than change their systems so that an alphabetic character appears in position 7 of the VIN to comply with today's rule.

For all other VIN positions, these manufacturers may continue to use current systems to generate VIN characters using the old character limitations. Because of the change from a numeric character to an alphabetic character in position 7, unique VINs will be assured. These manufacturers will be able to adjust their systems as needed over time to be able to generate VIN characters under the expanded options for characters contained in the final rule.