Interpretation ID: aiam4099
Manager
Engineering
Isuzu Motors America
Inc.
21415 Civic Center Drive
Southfield
MI 48076- 3969;
Dear Mr. Tokunaga: This letter responds to your inquiry of June 25, 1986, requesting a interpretation of S4.5 of Standard No. 115, *Vehicle Identification Number--Basic Requirements*, regarding the 'part of the vehicle' on which the vehicle identification number (VIN) should appear. I regret the delay in replying to your letter.; You ask whether either of two specific locations within the passenge compartment of a vehicle would meet the VIN location requirement, and submit diagrams of these locations. Paragraph S4.5 of Standard No. 115 reads:; >>>'The VIN of each vehicle shall appear clearly and indelibly upo either a part of the vehicle other than the glazing that is not designed to be removed except for repair or upon a separate plate or label which is permanently affixed to such a part.'<<<; You state in you letter that your concern is whether a VIN or a plat or label with the VIN affixed to it, may be 'fitted to a part that is not designed to be removed except for repair but that can be replaced by a new part as a result of the repair.'; We interpret S4.5 to require that the VIN be placed on a part that i designed to be removed only for the purpose of repairing (or replacing) that part. Thus, the VIN may not be placed on a part which is designed to be removed to allow the maintenance or repair of other parts.; The first location you describe is the instrument panel front cover That cover is a plastic strip immediately behind and below the inner surface of the front windshield, and it appears from your diagram that the part is designed to be removed only for its repair or replacement. If that is correct, placing the VIN at this location would meet the requirement of S4.5.; The second location is the top of the meter upper hood. On you diagram, this location seems to be on the plastic cover for the speedometer and tachometer. It appears from the diagram that the meter upper hood is designed to be removed to permit the repair or maintenance of those meters or other parts of the dash board. If this is the case, then this location would not comply.; As a separate matter, we note from your diagram that the meter hoo location may be in a passenger car, multipurpose passenger vehicle, or light truck. If that is so, you must meet both the S4.5 requirement with respect to placement of the VIN, and the readability requirement of S4.6.; I hope this information is helpful to you. Sincerely, Erika Z. Jones, Chief Counsel