Mr. Jerome A. Hoover
Compliance Engineer
Monaco Coach Corporation, Indiana Division
P. O. Box 4313
Elkhart, IN 46514-0313

Dear Mr. Hoover:

This responds to your request for an interpretation whether a world manufacturer identifier (WMI) assigned to Roadmaster Rail, Inc. (Roadmaster) can continue to identify Roadmaster after Monaco Coach Corporation (Monaco) purchases Roadmaster. Under the facts described below, since Monaco is not assigned a WMI and intends to continue use of the Roadmaster name, Monaco may use Roadmaster's WMI.

Your letter states Roadmaster and Holiday Rambler are divisions of Monaco. Roadmaster manufactures incomplete vehicles, and Holiday Rambler and Monaco are final stage vehicle manufacturers. You wrote that "Monaco has full liability for the Roadmaster chassis, and for Monaco and Holiday Rambler motorhomes."

In a telephone conversation with Dorothy Nakama of my staff, you explained that Monaco does not manufacture any vehicles in one stage or any incomplete vehicles, and is not assigned a WMI. You stated that before Monaco acquired Roadmaster in 1993, Roadmaster was an independent company, not part of another company. You stated that Monaco does not intend to merge Roadmaster into Monaco but to keep Roadmaster as a separate division, and to advertise Roadmaster as a trade name. You also stated that Holiday Rambler was once an independent company and is assigned its own WMI because it manufacturers trailers and fifth wheels.

NHTSA's regulations at 49 CFR Part 565 Vehicle Identification Number Requirements states that the WMI shall "uniquely identify the manufacturer, make and type of the motor vehicle if its manufacturer produces 500 or more motor vehicles of its type annually." (49 CFR section 565.6(a)) In past interpretation letters, NHTSA has interpreted "uniquely identify" to mean that the same WMI cannot be used for two corporate entities if there is a possibility the two entities will be confused.

Your case is one of first impression. Unlike similar situations we have addressed, no WMI is assigned to the parent company (Monaco), but each division (Roadmaster and Holiday Rambler) has a separate WMI. You assure us that there are no plans for Monaco to be a one stage vehicle manufacturer or an incomplete vehicle manufacturer (which would require assigning a WMI).

Since Monaco itself is not assigned a WMI, and but each of its divisions, Roadmaster and Holiday Rambler has separate WMIs, we agree that Roadmaster and Holiday Rambler may continue to use the WMI assigned to each company. Under the facts described, there would be no confusion as to which corporate entity manufactured the applicable vehicle. Also, separate WMIs for the two divisions make it possible to distinguish between vehicles built by Roadmaster and Holiday Rambler.

I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992.

Sincerely,

John Womack

Acting Chief Counsel

ref:565

3/20/97