Manager, Compliance & Technical Liaison
Saab Cars USA, Inc.
4405 - A International Blvd.
Norcross, GA 30093
Dear Mr. Plante:
This responds to your request for an interpretation whether, in a vehicle identification number (VIN), the third position in the fourth section (the twelfth position overall) can be designated with an alphabetical letter, rather than a number. As provided below, the answer is yes.
NHTSA's VIN regulations are at 49 CFR Part 565, Vehicle Identification Number Requirements. Section 565.6, Content requirements, states that the VIN consists of four sections of characters and describes each section. Section 565.6(d)(3) states that: "The third through the eighth characters of the fourth section [i.e., the twelfth through the seventeenth positions of the VIN] shall represent the number sequentially assigned by the manufacturer in the production process if the manufacturer produces 500 or more vehicles of its type annually." (Emphasis added.)
You state that Saab wishes to use an alphabetical letter in the twelfth position of the VIN to "denote the introduction of significant running changes" during a model year. As an example, if a significant running change is made in production beginning with the 25,001 produced vehicle, VIN positions twelve through seventeen would go from A25000 to B25001. Your letter states that positions thirteen through seventeen would remain as sequential serial numbers.
In a telephone conversation with George Entwistle and Dorothy Nakama of this agency, you explained that Saab manufactures fewer than 100,000 worldwide of any Saab model in any model year, and does not use the twelfth position for numbering its vehicles. You also stated that Saab does not wish to use a number in the twelfth position because those unfamiliar with the Saab VIN numbering system may look at the twelfth position and get the mistaken impression that 100,000 or 200,000 of a particular model have been manufactured.
For the following reasons, Saab may use the twelfth VIN position to designate significant running changes made in vehicle production during a model year. The views offered in this interpretation letter are limited to the twelfth VIN position. This letter is also limited to situations where fewer than 100,000 vehicles are manufactured for the U.S. market in a model year.
In a VIN, the twelfth through seventeenth positions (a total of six positions) are available so that manufacturers can number the production sequence of a particular vehicle model in the hundreds of thousands. Because Saab produces fewer than 100,000 of each of its models, the twelfth position presumably has an "0" occupying it. We do not believe there would be ambiguity about or misunderstanding of the meaning of the twelfth position if we permitted use of an alphabetical letter, instead of the 0. The twelfth through the seventeenth positions would "represent" the number sequentially assigned by the manufacturer in the production process, as required by 565.6(d)(3).
In allowing your use of a letter in the twelfth position for production of fewer than 100,000 vehicles, we considered that the purpose of the VIN is "to simplify vehicle identification information retrieval and to increase the accuracy and efficiency of vehicle recall campaigns." (49 CFR 565.1) Identifying significant running changes during the course of a model year could increase the accuracy and efficiency of recall campaigns by limiting the affected vehicles to those manufactured during a specified running change, rather than affecting the entire production run of a model during a model year.
If Saab uses the twelfth VIN position to designate running changes with alphabetical letters, it must comply with the following. Section 565.7(c) requires that manufacturers shall submit to NHTSA the information necessary to decipher the characters contained in its VINs. Amendments to the information shall be submitted to the agency for VINs containing an amended coding. Section 565.7(d) specifies that the information required under paragraph (c) shall be submitted at least 60 days prior to offering for sale the first vehicle identified by a VIN containing that information. Thus, you must inform NHTSA at least 60 days before the offer for sale of the first vehicle with a VIN containing a letter in the twelfth position. Also, Saab must ensure that the letters assigned in the twelfth position are sequentially assigned and are the letters specified in Section 565.4(g). Saab need not notify this agency every time a letter in the twelfth position is changed.
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.
Acting Chief Counsel