Interpretation ID: aiam4421
Jr.
Esq.
Assistant General Counsel
Fruehauf Corporation
Law Department
10900 Harper Avenue
P.O. Box 238
Detroit
MI 48232;
Dear Mr. Bourbeau: This letter responds to your earlier inquiry where you ask whethe NHTSA would object to your Company's changing 'its model year designation from September 1 to July 1.' I apologize for the delay in responding.; Standard 115, *Vehicle Identification Number-Basic Requirements* directs vehicle manufacturers to place a discrete identifying number (VIN) on each vehicle. Title 49 CFR Part 565, *VIN-Content Requirements*, states that a VIN must include a character indicating the manufacturer's designated model year. Neither Standard 115 nor Part 565 prohibits your company from changing the model year in the manner you suggest. Therefore, such a change does not violate our regulations.; We note that this change apparently concerns model year as a marketin concept. The Federal Trade Commission has published guidelines concerning model year as a commercial concept, and you may wish to contact the Commission for whatever assistance it may provide. I hope you find this information helpful.; Sincerely, Erika Z. Jones, Chief Counsel