ID: 86-4.18

TYPE: INTERPRETATION-NHTSA

DATE: 07/21/86

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: TAKESHI TANUMA -- NISSAN RESEARCH & DEVELOPMENT, INC.

TITLE: NONE

ATTACHMT: LETTER DATED 12/19/85 TO ERIKA Z JONES, FROM TAKESHI TANUMA, OCC-0023, RE W-139-H

TEXT: Dear Mr. Tanuma:

This responds to your letter of December 19, 1985, asking whether an antitheft device installed in all but a few cars of a particular car line would be considered "standard equipment" under Title VI of the Motor Vehicle Information and Cost Savings Act. As explained below, the answer to your question is no.

You describe a situation in which 99.9% of "A" model vehicles were equipped with an antitheft device in Model Year 1985. Specifically, your letter states that total sales in the United States for that model year were 101,854 vehicles. Of these, 101,758 vehicles were equipped with an antitheft device; the rest or 96 vehicles, which were shipped to Hawii, Guam, and Saipan as rental cars, were not equipped with an antitheft device. You state that you expect 99.9% of "A" model cars to be equipped with an antitheft device in Model Year 1987 and ask if, under these circumstances, the antitheft device can be considered standard equipment.

Under section 605(a) of the Motor Vehicle Information and Cost Savings Act, any manufacturer may petition this agency for an exemption from the vehicle theft prevention standard for any "line or lines of passenger motor vehicle which are equipped as standard equipment with an antitheft device" which the agency determines is likely to be as effective in reducing and deterring motor vehicle theft as compliance with the standard. This section also defines "standard equipment" as that installed at the time the vehicle is delivered from the manufacturer and which is not an accessory or other item which the first purchaser customarily has the option to have installed.

As interpreted by this agency, "standard equipment" refers to antitheft devices that are provided without extra charge on all vehicles of a particular line which are introduced into the commerce of the United States or imported and which are not intended solely for export and exported. Since the antitheft device in your example would not be installed in all model "A" cars imported into the United States, the agency concludes that the device would not be standard equipment within the meaning of section 605.

Sincerely,

ID: nht87-1.23

TYPE: INTERPRETATION-NHTSA

DATE: 01/16/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Peter Cameron-Nott

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Peter Cameron-Nott 90 Horace Street Startford, CT 06497

Dear Mr. Cameron-Nott:

This is in reply to your letter of December 7, 1986, with respect to kit cars.

Your first question concerns a 1965 Jaguar that has been rebodied but carries its original mechanical components, title, and identification number. The National Traffic and Motor Vehicle Safety Act does not require conformance with the Federal motor vehi cle safety standards applicable to passenger cars if the passenger car to be imported into the United States was manufactured before January 1, 1968. However, certain of these standards cover vehicle components, and if the relevant components have been m anufactured on or after January 1, 1968, these components would be subject to the applicable Federal safety standard. These components include brake hoses, lighting equipment, tires, retreaded tires, glazing materials (most importantly, the windshield mu st be marked AS-1), seat belt assemblies, and wheel covers (which may not incorporate winged projections). Although the 1965 Jaguar would have a new body, by retaining its original mechanical components, title, and identification number, it would be cons idered a 1965 model and not subject to the Federal motor vehicle safety standards applicable to passenger cars. But if any of the equipment listed above has been manufactured after January 1, 1968, those items must comply in order to be imported into thi s country.

You have asked how the situation would differ were the rebodied Jaguar a 1972 model, the other facts being identical. We would consider this car " a 1972 model, and required to conform to all Federal motor vehicle safety standards that applied on the dat e of its original manufacture. Conformity could be achieved either before or after its importation into this country.

Your second question concerns "a kit car consisting of both new and used components i.e. new body/chassis and used mechanicals from various sources including Ford/Triumph and M.G." You have reported EPA's position that the year of the engine determines what standards are to be met, and you have asked if these are also DOT's requirements. The age of the engine is not the determining factor with us. Generally, the agency considers a kit car consisting of a new body and new chassis to be a new motor vehicle, and required to meet all Federal motor vehicle safety standards applicable to new passenger cars as of the date of its assembly, even if some of its mechanical components have been used previously . This means that such components must not prevent the assembled vehicle from meeting those standards.

If you have further questions we would be pleased to answer them.

Sincerely,

Erika Z. Jones Chief Counsel

Ms. Erika Jones Chief Counsel 12/7/86 N.H.T.S.A. 400 7th St S.W. Washington D.C. 20590

Dear Ms. Jones:

I recently spoke to Mr. John Donaldson at D.O.T and he recommended that I write to you concerning importation of rebodied and kit vehicles. There are some points upon which I would request further clarification.

I wish to import the following vehicles:

#1 1965 Jaguar that has been rebodied but still using original mechanical components. i.e. new body and original Jaguar mechanicals including suspension, steering, brakes, transmission etc.

The chassis carries the original 1965 Jaguar I.D. # and is titled accordingly i.e. 1965 Jaguar two seat convertible and 1965 I.D. #.

In addition what standards are applicable if the rebodied vehicle is for example a 1972 Jaguar and titled as such?

#2 A kit car consisting of both new and used components i.e. new body/chassis and used mechanicals from various sources including Ford/Triumph and M.G.

E.P.A. has informed me that in these cars the rebodied 65 jaguar is exempted because it was originally manufactured prior to 1968 but the 1972 Jaguar must be certified to 1972 standards. And for the kit car the year of the engine in the vehicle determine s what standards must be met. Are these also the requirements of D.O.T.?

Your clarification of these points would be greatly appreciated.

Sincerely Yours,

Peter Cameron-Nott

ID: nht93-6.46

DATE: September 27, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Joel Trim -- Manager, Mechnical Service Department, Neal and Massy Motors

TITLE: None

ATTACHMT: Attached to letter dated 7/7/93 from Joel Trim to The Secretary, U.S. Department of Transportation (OCC-8902)

TEXT:

We have received your letter of July 7, 1993, asking the Secretary of Transportation for assistance in obtaining copies of any regulations and standards that govern the certification and operation of modified vehicles (stretch limousines), kit cars, and homemade vehicles. Your country, Trinidad, has no such regulations.

Under the dual Federal-State system of government in the United States, the registration, inspection, and operation of motor vehicles is a State function. We are unable to advise you on the laws of the individual States, but you may find assistance by writing the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, VA 22203.

Federal regulation of motor vehicles is primarily concerned with establishing and enforcing standards to be met when the vehicle is manufactured, the Federal motor vehicle safety standards (FMVSS). With one minor exception the United States has no laws or regulations that apply specifically to the types of vehicles you have named. I am pleased, however, to explain how we have treated them over the years in the interpretive letters we have written.

A. Modified vehicles As you may know, each vehicle manufactured for sale in the United States must bear its manufacturer's label certifying that it complies with all FMVSS. If a vehicle is modified after it has left the factory and before it is sold, the modifier is required to affix its own label stating that the vehicle as modified complies with all FMVSS affected by the alteration. However, this label is not required if the modifications are minor changes affecting readily attachable equipment items. Further, under our law, no label is required if the vehicle is modified after it has been sold. I enclose a copy of our certification regulation, 49 CFR Part 567 and call your attention to Section 567.7 Requirements for persons who alter certified vehicles.

We have discovered instances in which modified vehicles (stretch limos) failed to conform to the FMVSS on braking and passenger protection. In accordance with our procedures, the modifiers were required to correct the noncompliances and to pay civil penalties for their violations.

B. Kit cars We have no definition of "kit cars" but we understand them to be passenger cars consisting of a mixture of old and new parts, assembled into vehicle form by either the supplier or purchaser of a kit of motor vehicle equipment. Some of the FMVSS apply to individual equipment items (for example, tires, glazing, seat belt assemblies), and if these items are new and furnished with the kit,

they will have been certified by their manufacturers. If the vehicle is assembled entirely from new parts, the kit supplier must furnish certification with the kit that, when assembled, the vehicle will comply with all applicable FMVSS. However, if the vehicle is manufactured incorporating a number of previously used parts, particularly involving the chassis and/or drive train, we generally have considered the vehicle to be a used one, and none of the FMVSS that apply to new completed vehicles (as contrasted with those that apply to equipment items) apply to it.

In order to be registered for use, a kit car must meet the requirements of the State of licensing.

C. Homemade cars We have no definition of a "homemade car" but we understand such a vehicle to be a "one-off" and not intended for production. The FMVSS apply to every newly manufactured vehicle without exception, so that a vehicle built in a series of one must conform to the FMVSS if it is constructed entirely from new parts, and if the agency has not exempted it from compliance.

A homemade car must meet the requirements of the State where it is to be licensed.

For your information, I am also enclosing a booklet containing a brief description of each FMVSS, and an order blank for "Title 49 Code of Federal Regulations Parts 400-999" which contains the complete text of the FMVSS. If you have any further questions on this subject, we will be happy to answer them.

ID: 8902

Mr. Joel Trim
Manager
Mechanical Service Department
Neal & Massy Motors
P.O. Box 1298
Port of Spain
Trinidad, West Indies

Dear Mr. Trim:

We have received your letter of July 7, 1993, asking the Secretary of Transportation for assistance in obtaining copies of any regulations and standards that govern the certification and operation of modified vehicles (stretch limousines), kit cars, and homemade vehicles. Your country, Trinidad, has no such regulations.

Under the dual Federal-State system of government in the United States, the registration, inspection, and operation of motor vehicles is a State function. We are unable to advise you on the laws of the individual States, but you may find assistance by writing the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, VA 22203.

Federal regulation of motor vehicles is primarily concerned with establishing and enforcing standards to be met when the vehicle is manufactured, the Federal motor vehicle safety standards (FMVSS). With one minor exception the United States has no laws or regulations that apply specifically to the types of vehicles you have named. I am pleased, however, to explain how we have treated them over the years in the interpretive letters we have written.

A. Modified vehicles As you may know, each vehicle manufactured for sale in the United States must bear its manufacturer's label certifying that it complies with all FMVSS. If a vehicle is modified after it has left the factory and before it is sold, the modifier is required to affix its own label stating that the vehicle as modified complies with all FMVSS affected by the alteration. However, this label is not required if the modifications are minor changes affecting readily attachable equipment items. Further, under our law, no label is required if the vehicle is modified after it has been sold. I enclose a copy of our certification regulation, 49 CFR Part 567 and call your attention to Section 567.7 Requirements for persons who alter certified vehicles.

We have discovered instances in which modified vehicles (stretch limos) failed to conform to the FMVSS on braking and passenger protection. In accordance with our procedures, the modifiers were required to correct the noncompliances and to pay civil penalties for their violations.

B. Kit cars We have no definition of "kit cars" but we understand them to be passenger cars consisting of a mixture of old and new parts, assembled into vehicle form by either the supplier or purchaser of a kit of motor vehicle equipment. Some of the FMVSS apply to individual equipment items (for example, tires, glazing, seat belt assemblies), and if these items are new and furnished with the kit, they will have been certified by their manufacturers. If the vehicle is assembled entirely from new parts, the kit supplier must furnish certification with the kit that, when assembled, the vehicle will comply with all applicable FMVSS. However, if the vehicle is manufactured incorporating a number of previously used parts, particularly involving the chassis and/or drive train, we generally have considered the vehicle to be a used one, and none of the FMVSS that apply to new completed vehicles (as contrasted with those that apply to equipment items) apply to it.

In order to be registered for use, a kit car must meet the requirements of the State of licensing.

C. Homemade cars We have no definition of a "homemade car" but we understand such a vehicle to be a "one-off" and not intended for production. The FMVSS apply to every newly manufactured vehicle without exception, so that a vehicle built in a series of one must conform to the FMVSS if it is constructed entirely from new parts, and if the agency has not exempted it from compliance.

A homemade car must meet the requirements of the State where it is to be licensed.

For your information, I am also enclosing a booklet containing a brief description of each FMVSS, and an order blank for "Title 49 Code of Federal Regulations Parts 400-999" which contains the complete text of the FMVSS. If you have any further questions on this subject, we will be happy to answer them.

Sincerely,

John Womack Acting Chief Counsel

Enclosures ref:567 d:9/27/93

ID: nht90-4.24

TYPE: Interpretation-NHTSA

DATE: September 26, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Roger C. Fairchild -- Esq., Shutler & Low

TITLE: None

ATTACHMT: Attached to letter dated 7-5-90 from R.C. Fairchild to P.J. Rice (OCC 4968)

TEXT:

This responds to your inquiry about Federal Motor Vehicle Safety Standards 109, 110, 119, and 120 on tires and rim selection (49 CFR 571.109, 571.110, 571.119, and 571.120), asking about the applicability of certain provisions in the Tire and Rim Associa tion (TRA) Year Book, which those Federal safety standards incorporate by reference. As explained below, we agree that the adjustment factors in the TRA Year Book for inflation pressures and load ratings at different speeds are not applicable in determi ning compliance with Federal safety standards.

By way of background, the National Traffic and Motor Vehicle Safety Act, (Vehicle Safety Act, 15 USC 1381 et seq.) requires every new motor vehicle sold in the United States to be certified as complying with all applicable Federal motor vehicle safety st andards. The Vehicle Safety Act specifies that the manufacturer must certify that each of its vehicles complies with all applicable safety standards in effect on the date of manufacture. Because of this statutory requirement, this agency does not appro ve any manufacturer's vehicles or offer assurances that the vehicles comply with the safety standards. Any person violating the Vehicle Safety Act by manufacturing or selling new noncomplying vehicles may be liable for potential penalties of $1,000 per violation up to $800,000.

Section S4.3 of Standard 109 requires a new pneumatic tire for passenger cars to be labeled with certain information including one size designation, the maximum inflation pressure, and the maximum load rating. S6.5 of Standard 119 has similar marking req uirements for tires on vehicles other than passenger cars. In particular, section 4.2.1(c) of Standard 109 and section 6.5(d) of Standard 119 require tires to be labeled with a maximum load rating not less than the lowest of any specified values in the manufacturer's submission or in a listed publication such as the TRA Yearbook, for tires of that size designation, type and each appropriate inflation pressure. For passenger car tires, these inflation pressures and load ratings are specified in tables in section one of the TRA Yearbook entitled, "'P' Type Tires Used on Passenger Cars and Station Wagons" and "'T' Type Spare Tires for Temporary use on Passenger Cars and Station Wagons." For tires on vehicles other than passenger cars, these inflation p ressures and load ratings are specified in the tables in section 2 of the TRA Yearbook.

Question One You first asked whether the Federal safety standards incorporate an independent vehicle speed adjustment factor in determining the "vehicle normal load" and "vehicle maximum load." Your question was based on provisions in the TRA Year Book which apply s uch a vehicle load adjustment factor for certain tires rated for a maximum speed above 130 mph. As you

are aware, S4.2 of Standard 110 provides that the vehicle maximum load on the tire shall not be greater than the applicable maximum load rating marked on the tire, and the vehicle normal load on the tire shall not be greater than the test load used in St andard 109's high speed performance test.

You are correct that an adjustment factor based on the vehicle's maximum speed capacity is not required to be used in determining compliance with Standard 110 and 120. As you noted, Standard 110's requirement, as specified in S4.2.2, takes into account an adjustment for high speed use by requiring that the normal vehicle load on a tire must not exceed the test load used in Standard 109's high speed performance test in S5.5 (i.e. 88 percent of the tire's maximum load rating). Based on this provision an d Standard No. 110's use of the terms "vehicle maximum load" and "maximum loaded vehicle weight," we interpret S4.2 as applying to normal vehicle uses and not special high speed applications. In fact, incorporating a load adjustment factor based on spee ds of 130 to 168 mph, as the TRA provision does, would be contrary to motor vehicle safety if it encouraged vehicle operation at speeds far exceeding safe operating speeds. Therefore, the general tables in the TRA Yearbook listing maximum inflation pres sures and maximum load ratings, standing alone without applying any adjustment factor, are the applicable values in determining compliance with the Federal safety standards.

Question Two You also asked about a vehicle speed adjustment factor for the inflation pressure with passenger cars. As you explained, the TRA Year Book requires that the "speed category of the tire must match or exceed the theoretical maximum speed of the vehicle (i .e., actual maximum speed, as adjusted for tire inflation pressure using another factor specified by TRA)." TRA sets forth two speed categories: speeds up to 210 km/h (130 mph) and speeds above 210 km/h (130 mph).

As with the vehicle load adjustment factor which concerns normal vehicle applications, you are correct that an adjustment factor for inflation pressure based on the vehicle's maximum speed is not required to be used in determining compliance with Federal safety standards. Again, the general tables in the TRA Yearbook listing maximum inflation pressures and maximum load ratings, standing alone without applying any adjustment factor, are the applicable values in determining compliance with the Federal sa fety standards.

Question Three You then asked about the applicability to the Federal standards of TRA's recommended adjustments for tire inflation pressure and "service load" for tires used on trucks and buses, depending on the maximum speed capability of the vehicle. As with the adj ustment factors for passenger car tires, these adjustment factors are not relevant for compliance with Standard 119 or 120. Again, the general tables in the TRA Yearbook listing maximum inflation pressures and maximum load ratings, standing alone withou t applying any adjustment factor, are the applicable values in determining compliance with the Federal safety standards.

I hope this information is helpful. If you have any further questions,

please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

ID: 2672y

Roger C. Fairchild, Esq.
Shutler & Low
14500 Avion Parkway, Suite 300
Chantilly, VA 22021-1101

Dear Mr. Fairchild:

This responds to your inquiry about Federal Motor Vehicle Safety Standards 109, 110, 119, and 120 on tires and rim selection (49 CFR 571.109, 571.110, 571.119, and 571.120), asking about the applicability of certain provisions in the Tire and Rim Association (TRA) Year Book, which those Federal safety standards incorporate by reference. As explained below, we agree that the adjustment factors in the TRA Year Book for inflation pressures and load ratings at different speeds are not applicable in determining compliance with Federal safety standards.

By way of background, the National Traffic and Motor Vehicle Safety Act, ("Vehicle Safety Act," 15 USC 1381 et seq.) requires every new motor vehicle sold in the United States to be certified as complying with all applicable Federal motor vehicle safety standards. The Vehicle Safety Act specifies that the manufacturer must certify that each of its vehicles complies with all applicable safety standards in effect on the date of manufacture. Because of this statutory requirement, this agency does not approve any manufacturer's vehicles or offer assurances that the vehicles comply with the safety standards. Any person violating the Vehicle Safety Act by manufacturing or selling new noncomplying vehicles may be liable for potential penalties of $1,000 per violation up to $800,000.

Section S4.3 of Standard 109 requires a new pneumatic tire for passenger cars to be labeled with certain information including one size designation, the maximum inflation pressure, and the maximum load rating. S6.5 of Standard 119 has similar marking requirements for tires on vehicles other than passenger cars. In particular, section 4.2.1(c) of Standard 109 and section 6.5(d) of Standard 119 require tires to be labeled with a maximum load rating not less than the lowest of any specified values in the manufacturer's submission or in a listed publication such as the TRA Yearbook, for tires of that size designation, type and each appropriate inflation pressure. For passenger car tires, these inflation pressures and load ratings are specified in tables in section one of the TRA Yearbook entitled, "'P' Type Tires Used on Passenger Cars and Station Wagons" and "'T' Type Spare Tires for Temporary Use on Passenger Cars and Station Wagons." For tires on vehicles other than passenger cars, these inflation pressures and load ratings are specified in the tables in section 2 of the TRA Yearbook. Question One You first asked whether the Federal safety standards incorporate an independent vehicle speed adjustment factor in determining the "vehicle normal load" and "vehicle maximum load." Your question was based on provisions in the TRA Year Book which apply such a vehicle load adjustment factor for certain tires rated for a maximum speed above 130 mph. As you are aware, S4.2 of Standard 110 provides that the vehicle maximum load on the tire shall not be greater than the applicable maximum load rating marked on the tire, and the vehicle normal load on the tire shall not be greater than the test load used in Standard 109's high speed performance test.

You are correct that an adjustment factor based on the vehicle's maximum speed capacity is not required to be used in determining compliance with Standard 110 and 120. As you noted, Standard 110's requirement, as specified in S4.2.2, takes into account an adjustment for high speed use by requiring that the normal vehicle load on a tire must not exceed the test load used in Standard 109's high speed performance test in S5.5 (i.e. 88 percent of the tire's maximum load rating). Based on this provision and Standard No. 110's use of the terms "vehicle maximum load" and "maximum loaded vehicle weight," we interpret S4.2 as applying to normal vehicle uses and not special high speed applications. In fact, incorporating a load adjustment factor based on speeds of 130 to 168 mph, as the TRA provision does, would be contrary to motor vehicle safety if it encouraged vehicle operation at speeds far exceeding safe operating speeds. Therefore, the general tables in the TRA Yearbook listing maximum inflation pressures and maximum load ratings, standing alone without applying any adjustment factor, are the applicable values in determining compliance with the Federal safety standards.

Question Two You also asked about a vehicle speed adjustment factor for the inflation pressure with passenger cars. As you explained, the TRA Year Book requires that the "speed category of the tire must match or exceed the theoretical maximum speed of the vehicle (i.e., actual maximum speed, as adjusted for tire inflation pressure using another factor specified by TRA). TRA sets forth two speed categories: speeds up to 210 km/h (130 mph) and speeds above 210 km/h (130 mph).

As with the vehicle load adjustment factor which concerns normal vehicle applications, you are correct that an adjustment factor for inflation pressure based on the vehicle's maximum speed is not required to be used in determining compliance with Federal safety standards. Again, the general tables in the TRA Yearbook listing maximum inflation pressures and maximum load ratings, standing alone without applying any adjustment factor, are the applicable values in determining compliance with the Federal safety standards.

Question Three You then asked about the applicability to the Federal standards of TRA's recommended adjustments for tire inflation pressure and "service load" for tires used on trucks and buses, depending on the maximum speed capability of the vehicle. As with the adjustment factors for passenger car tires, these adjustment factors are not relevant for compliance with Standard 119 or 120. Again, the general tables in the TRA Yearbook listing maximum inflation pressures and maximum load ratings, standing alone without applying any adjustment factor, are the applicable values in determining compliance with the Federal safety standards.

I hope this information is helpful. If you have any further questions, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:l09#ll0#ll9#l20 d:9/26/90

ID: nht80-3.44

DATE: 08/29/80

FROM: FRANK BERNDT -- CHIEF COUNSEL, NHTSA; SIGNATURE BY STEPHEN P. WOOD

TO: Aston Martin Lagonda (1975) Limited

TITLE: FMVSS INTERPRETATION

TEXT: I have in hand your letter of July 31, 1980, and regret to inform you that the vehicle identification number (VIN) scheme which you propose is apparently not in compliance with U.S. Federal Motor Vehicle Safety Standard No. 115.

S4.5.2 and Table 1 of Standard No. 115 provide that the following information shall be decipherable from the five characters comprising the second section of the VIN for passenger cars: Line, Series, Body Type, Engine Type, Restraint System Type. A review of your Engineering Instructions and the accompanying drawings do not provide information concerning either the engine type or the restraint system type. Likewise, it is not clear whether your model designation is more appropriately characterized as line and/or series.

If the information omitted remains constant throughout a particular model, it will only be necessary for you to so state when deciphering your model code. For example, the following would be permissible:

Position 5 and 6: "V8" means V8 Volante model LHD, seat belt manual restraint system, V-8 engine with a displacement of 5.3 liters/326 cubic inches, a compression ratio of 8.3 and a net brake horsepower of .

We would also call to your attention that gross vehicle weight class is not required to be encoded in the VIN, although you are free to do so if you so choose.

Amongst the material furnished to the agency were drawings indicating the location of your confidential chassis identification number. As these are not required to be forwarded to the agency, I have taken the liberty of destroying them.

SINCERELY,

ENCLS.

ASTON MARTIN LAGONDA (1975) LIMITED

Frederic Schwartz Officer of the Chief Counsel, N.T.S.A.,

JULY 31, 1980

Dear Mr. Schwartz,

Vehicle Identification Numbering (17 characters)

Please find enclosed details upon which the Aston Martin Lagonda (1975) Ltd.

company has based its vehicle identification number (VIN) system, to be introduced with our 1981 model year cars.

The following documents have been enclosed to help clarify and explain the construction of the VIN system in detail:

(a) Construction drawings B97-16204/5/6 apply to Aston Martin V8 Saloon, Volante and Vantage (LHD) models respectively, B97-16224 applies to the Lagonda (LHD) (not currently certified in USA).

(b) Engineering Instruction number 205 gives a detailed explanation of the VIN construction. Engineering Instructions are sent to various departments within the Aston Martin organization and act as a reference and guide upon which work is carried out.

(c) Drawings A97-16226 and A97-16544 show the VIN plate designs and locations on the vehicle. The VIN is also stamped on the chassis member in characters with a minimum height of 7 mm (0.28 inches), Figures 1 and 2 in Engineering Instruction 205 show the location.

We have not sent details of our VIN system to anyone else, therefore we would appreciate your forwarding this letter and its contents to the relevant U.S. department, or advising accordingly.

KINDEST REGARDS,

R. Goldsmith Certification Engineer Safety and Emissions Department

ENGINEERING INSTRUCTION no. 205

Vehicle Identification Number (VIN) Systems

1. INTRODUCTION

AML will soon be operating two distinct Vehicle Identification Number (VIN) systems, one system applying to cars sold to U.S.A. and Canada and the other system applying to cars sold elsewhere in the world.

2. U.S.A. AND CANADA VIN SYSTEM (NHTSA)

1981 and subsequent model year cars sold to U.S.A. and Canada are required to have a 17 (seventeen) character vehicle identification number assigned. This means a series of arabic numbers and roman letters assigned to each motor vehicle for identification purposes and shall be sans sarif type face with a minimum height of 4 mm.

The VIN shall appear clearly and indelibly (i.e. stamped) on:

(a) the vehicle certification label (i.e. the brass plate, part number A97-13074, fixed to left hand 'B' post), and

(b) the VIN label part number A97-16226 and fixed in the same manner and position as the superceded label, part number 071-50-0160, on the dashboard.

2.1 VIN Content and Structure The VIN content and structure is as follows:

STRUCTURE

RACTER POSITION

1)

2) Assigned by BSI

3)

4) Gross vehicle weight class. 'C' = 4001 to 5000 lbf 'D' = 5001 to 6000 lbf

5)

6) Model

7 Not used

8 Model variant

9 Check digit (see R.G.'s memo for detailed explanation)

10 Model Year. 'A' = 1980

11 Plant of manufacture. 'T' = Tickfords

12 Driving position. 'T' = (Illegible Words) A = 1 J = 1 T = 3 B = 2 K = 2 U = 4 C = 3 L = 3 V = 5 D = 4 M = 4 W = 6 E = 5 N = 5 X = 7 F = 6 P = 7 Y = 8 G = 7 R = 9 Z = 9 H = 8 S = 2

VIN: S C F C V 8 0 S A Assigned value: 2 3 6 3 5 8 0 2 0 1 Weight factor: 8 7 6 5 4 3 2 10 0 9 Product: 16 21 36 15 20 24 0 20 0 9

2.1.1 World Manufacturers Identifier (WMI) Section

The WMI section is located in character positions 1 to 3 inclusive and is assigned by B.S.I. The code for all our models is SCF.

2.1.2 Vehicle Description Section (VDS)

The VDS is located in character positions 4 to 8 and is assigned by the manufacturer within the constraints laid down in the USA Federal Register, volume 44, number 57.

2.1.3 Vehicle Indicator Section (VIS)

The VIS is located in character positions 10 to 17 inclusive and is also assigned by the manufacturer within the constraints in the Federal Register.

2.1.4 The Check Digit

The check digit shall be determined and included in the VIN for each car sold to North America and Canada. It is determined by carrying out a mathematical computation that utilises each of the VIN characters according to the following formula:

(a) Each alphabetic character is assigned a numeric value according to the following table:

(b) The assigned value for each character is then multiplied by a weight factor that is dependent on VIN character position, see worked example below.

(c) The products are then added together and the sum divided by 11.

(d) The check digit is the remainder of the division, when this is 10 the check digit is X; when zero the check digit remains zero.

Worked example

VS Saloon (LHD) with assumed chassis number 12456 VIN: T L 1 2 4 5 6 Assigned value: 3 3 1 2 4 5 6 Weight factor: 8 7 6 5 4 3 2 Product: 24 21 6 10 16 15 12

Sum of products = 265, divide by 11 = 24 1/11

*Thus the check digit = 1 (to be inserted in ninth character of VIN)

2.1.4.1 Check Digit - Simplification

Because many of the VIN characters are common to each model the check digit

The scheme works thus:

(a) The Intermediate Check Digit remains constant for each model variant.

(b) Having allocated the sequential chassis number, multiply each digit by its weight factor and add these products to find the sum.

(c) Referring to Table 1(a), line-up the appropriate Sum and read across to the next column for the Sequential Number Check Digit (SCD).

(d) Next, refer to Table 1(b), and in the first column line-up the Sequential Number Check Digit, then line-up the Intermediate Check Digit; the point where the column and rows intercept is the corresponding VIN Check Digit.

(e) A worked example of the simplified Check Digit determination is shown below.

V8 SALOON APPROX. LHD

VIN Prefix Sequential Chassis No.

SCFCV80S ATL12678

4 3 2

Sum = 61 = 24+21+16

Sequential No. Check Digit = 6 [From Table 1(a)]

Intermediate Check Digit = 2

VIN Check Digit = 8 (Illegible Words)

(f) A summary of the Intermediate Check Digits for our model range is listed below: Model Driving Intermediate Instruction Drawing position Check Digit Number V8 Saloon Left HD 2 B97-16204 " Right HD 0 B97-16211 V8 Volante Left HD 5 B97-16205 " Right HD 3 B97-16212 V8 Vantage Left HD - B97-16206 " Right HD 8 B97-16213 Lagonda Left HD 4 B97-16224 " Right HD 2 B97-16225

* APPLICABLE (Illegible Words) VIZ (Illegible Words)

3. VIN SYSTEM - BEST OF THE WORLD (i.e. not applicable to USA or Canada)

The vehicle identification number (VIN) section on the brass plate, part numbers A97-15564/5 applicable to the Lagonda and V8 models respectively, will be completed by AML using the current sequential chassis numbering system. The plates will be embossed using stamps with a character of 4 mm minimum height. There will be no gaps or marks between the characters. The number will be finished with a dash, again without a gap, similar to the start of the number as shown in drawing A97-15564/5.

The chassis numbering (VIN) system is as follows:

(a) Lagonda : -LOOR13XXX-

(b) V8 Saloon : -V8SOR12XXX-

(c) V8 Volante : -V8COR15XXX- and (d) V8 Vantage : -V8VOR12XXX-

3.1 Lagonda VIN Structure Lagonda VIN Structure CHARACTER POSITION 1 -L Model 2 0 Not yet designated 3 0 Not yet designated, but J to be used for cars sold to Japan 4 R R = Right hand drive; L = Left hand drive 5 1) Chassis number model variant prefix 6 3) 7 X) 8 X) Sequential chassis number 9 X-

3.2 V8 VIN Structure V8 VIN STRUCTURE CHARACTER POSITION 1 -V) Model 2 8) 3 S,C or V Variant, i.e. S = Saloon; C = Convertible & V = Vantage 4 0 Not yet designated, but 'J' to be used for care sold to Japan 5 R or L R = Right hand drive; L = Left hand drive 6 I) Chassis number model variant prefix 7 2 or 5) 8 X) 9 X) Sequential chassis number 10 X-

3.3 Location of VIN Chassis Stamping

Bearing in mind the points outlined in 3. above, the VIN will also be stamped in the RHS of the chassis in the locations indicated in Figures 1 and 2 applicable to the Lagonda and V8 models respectively. The character heights shall be a minimum 7 mm high, and the number shall be legible when the car is completed and ready for sale, i.e. not covered by underseal.

APPROVED BY: S. COUGHLIN

PREPARED BY: A. GOLDSMITH

SAFETY & EMISSIONS: J. D. ORCHARD

Table 1

(a) Sequential No. Check Digit (SCD) Sum SCD Sum SCD Sum SCD 1 1 36 3 71 5 2 2 37 4 72 5 3 3 38 5 73 7 4 4 39 6 74 8 5 5 40 7 75 9 6 6 41 8 76 10 7 7 42 9 77 0 8 8 43 10 78 1 9 9 44 0 79 2 10 10 45 1 80 3 11 0 46 2 81 4 12 1 47 3 13 2 48 4 14 3 49 5 15 4 50 6 16 5 51 7 17 6 52 8 18 7 53 9 19 8 54 10 20 9 55 0 21 10 56 1 22 0 57 2 23 1 58 3 24 2 59 4 25 3 60 5 26 4 61 6 27 5 62 7 28 6 63 8 29 7 64 9 30 8 65 10 31 9 66 0 32 10 67 1 33 0 68 2 34 1 69 3 35 2 70 4

(b) VIN Check Digit

Intermediate Check Digit (Illegible Table)

ID: nht90-4.59

TYPE: Interpretation-NHTSA

DATE: November 9, 1990

FROM: Joe W. Humphrey

TO: Paul Jackson Rice

TITLE: None

ATTACHMT: Attached to letter dated 12-13-90 to J.W. Humphrey from P.J. Rice (A36; Std. 108)

TEXT:

I have an idea for the safety of cars (illegible) for truckers. Will it be excepted in the federal law to add (illegible) lights to the center break lights in the back of cars above the back seat the break light red in the center orange or yellow on each side for (illegible). Lights all of them in the center of the cars for breaks and (illegible) lights only if this is excepted send me letter of approval please sir.

I hope you can understand what I am try to say.

ID: 86-1.50

TYPE: INTERPRETATION-NHTSA

DATE: 02/27/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Carol Lembke -- CL's Crafts and Florals

TITLE: FMVSS INTERPRETATION

TEXT:

Ms. Carol Lembke CL's Crafts & Florals 905 Cedar Street Charles City, Iowa 50616

This is in response to your letter of October 30, 1985, to Taylor Vinson of this office. You have asked about the legality under Federal Motor Vehicle Safety Standard No. 108 of "animals with lights in their eyes that work with the turn signals and brake lights to go in the backs of cars. The eyes are in red or amber".

We assume that you wish to sell these as accessories available in the aftermarket and not as original vehicle equipment. As these are not items of replacement lighting equipment but intended to supplement a vehicle's existing turn signal or stop lamp system, they are not covered by Standard No. 108 and their legality would be determined under the laws of a State where they would be in use. For example, you have told us that Iowa would allow these supplemental lamps. We recommend that you contact the American Association of Motor Vehicle Administrators once more, inform them that there is no Federal prohibition on this use, and ask their advice.

You have mentioned the center high-mounted stop lamp and whether your lights might be acceptable on cars of a certain age, and not on others. Standard No. 108 requires that each passenger car manufactured on or after September 1, 1985, be equipped with a third stop lamp mounted on the rear centerline not lower than three inches below the rear window (six inches on convertibles). In the initial year of use, the most frequently used area for mounting the lamp is the interior parcel shelf, where we presume that your supplemental lamp would be installed. Because your light would not meet the requirements for the center mounted lamp, it would be a violation of Federal law for a dealer, distributor, or motor vehicle repair business to remove the center mounted stop lamp and install your device. However, if the center mounted lamp is located in a place other than the parcel shelf, there would be no legal prohibition under Standard No. 108 forbidding the installation of your device on passenger cars manufactured on or after September 1, 1985.

I hope that this answers your questions.

Sincerely,

Erika Z. Jones Chief Counsel

CL's Crafts & Florals 905 Cedar St. Charles City, Iowa 50616 October 30, 1985 Taylor Vinson NHTSA - Legal Counsel 5219 U.S. Dept. of Transportation 400 7th St., SW Washington, DC 20590 Dear Sir: I am writing to ask assistance on the legality of a craft item I am making. I have a craft shop and attend craft shows. Recently I started making animals with lights in their eyes that work with the turn signals and brake lights to go in the back of the cars. The eyes are in red or amber. I checked with the Iowa State DOT and was told they would be ok since they were an ornament as long as they did not block view and had red or amber eyes. I've spoken to a Small Business Representative whom suggested I go mail order or sell to stores. I've also had interest from Florida and a Rod and Custom Club since they represent the fads of the 50's and 60's. I then became concerned about going into other states, their state laws and Federal laws that might not permit this item to be sold. I don't want to invest money and lots of time into this craft item only to find out that it is illegal and could come back on me. I've been told that a possible conflict could be a code number FMVSS 108. Something having to do with the new laws on the standard center mount lighting. I'm also wondering if this lighted animal might be ok for certain age cars and not others? I've made calls to DC to: American Assoc. of Motor Vehicles, NHTSA, and Federal Motor Vehicle Dept. of Trans. - only to get passed from one department to another till finally I was told to contact your office for assistance. I'm beginning to feel that this is one of those times that I should have taken my chances instead of trying to check things out to be legal. The interest is mounting in our Auto Animals for Christmas gifts and I have another show Nov. 9th. I would appreciate your response as soon as possible so that I will know if I can go ahead or not. Thank you. Sincerely, Carol Lembke 905 Cedar St. Charles City, IA 50616 Phone: 515-228-6913

ID: aiam1323

Dear Mr. Martin: This is in reply to your letter of November 9 to the U. S. Departmen of Transportation concerning the operation of 4-way flashers and brake lights on a 1972 Toyota.; Since there is no requirement that the hazard warning signal (4-wa flashers) be capable of operating independently of the stop signal, it is permissible for the stop signal to override the hazard warning signal. If fact, these signals on most passenger cars and multipurpose passenger vehicles manufactured in the United States operate similarly.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs;