Interpretation ID: nht80-2.1

DATE: 04/14/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: American Moped Associates

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of March 11, 1980, forwarding to Mr. Schwartz of my office the proposed vehicle identification number (VIN) scheme for American Moped Associates, and in confirmation of your subsequent telephone conversation with Mr. Schwartz.

Your VIN scheme complies with the requirements of Federal Motor Vehicle Safety Standard No. 115, with the following exceptions. The fourth through eighth characters of the VIN are required by S4.5.2 and Table I of the Standard to encode certain descriptive characteristics of the vehicle. For motorcycles, which include mopeds, this information is (1) type of motorcycle, (2) line, (3) engine type and (4) net brake horsepower. While the information which American Moped Associates proposed to encode in the fourth through eighth characters will undoubtedly be useful to your company, it is not necessary to advise the agency of your internal coding. Further, while much of the information the Standard requires to be decoded from these characters is self-evident because of your product line, it is none-the-less necessary to forward this information to the agency as specified in the Standard.

Based on your discussions with Mr. Schwartz, it appears this may be easily accomplished utilizing essentially the same format as you currently propose. It is my understanding that you no longer intend to encode the color in the fifth position of the VIN, but rather utilize a single "filler" character such as an "M". Further, I understand that all your mopeds utilize the same engine and comprise two lines characterized by the number of speeds. Consequently, based on your product line, your submission to the agency might read:

Characters 1-3 LAM: WMI assigned to American Moped Associates. Character 4 (internal use) Character 5 M: Indicates moped type; gasoline, one cylinder engine with a displacement of ; net-brake horsepower measured at the crankshaft of . Character 6 (internal use). Character 7 1 indicates one-speed Indian line. Character 7 1 indicates two-speed Indian line. Character 8 (internal use) Character 9 Check digit. Character 10 Model year. Character 11 T: Indicates Taipei plant of manufacture.

Y: Indicates Yuanlin plant of manufacture. Characters 12-17 Sequential number.

Please feel free to contact Mr. Schwartz should you have any further questions on this matter. Sincerely,

ATTACH.

AMERICAN MOPED ASSOCIATES

March 11, 1980

Frederic Schwartz -- Office of the Chief Counsel, National Highway Traffic Safety Administration

Dear Mr. Schwartz:

Pursuant to our recent telephone conversation concerning implementation of our VIN number, please find below for your approval a sample VIN number with notes explaining our coded identifiers.

LAMMB11A - AT123456

LAM - WMI assigned to American Moped Associates

M - Carburetor Type - alternate would be K

B - Color Black - G; Green - R; Red - W; White

1 - Wheel Type 1; Spoke - 2; Mag

1 - Number of Speeds 1; 1 Speed - 2; 2 Speed

A - Series changes letter from A to Z --- Check digit

A - Year of manufacture

T - Plant of mfr. T; Taipei - Y; Yuanalin

12346 - Numerical Sequence

If you have any questions, please feel free to call me at 1-800-854-6213.

Sincerely,

Bart Achille -- National Sales Manager