Interpretation ID: aiam3325
Quality Control Manager
Columbia Manufacturing Company
Westfield
Massachusetts 01085;
Dear Mr. Stevens: This is in response to your letter of June 17, 1980, and i confirmation of your several telephone conversations with Mr. Schwartz of my office.; In your letter, you asked whether the vehicle identification numbe (VIN) required by Federal Motor Vehicle Safety Standard No. 115 (46 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 the 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 moto 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 giv 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, Frank Berndt, Chief Counsel