Interpretation ID: 1985-01.26

TYPE: INTERPRETATION-NHTSA

DATE: 02/04/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Keith A. Sharp, Esq. Lillick, McHose & Charles

TITLE: FMVSS INTERPRETATION

TEXT:

Keith A. Sharp, Esq. Lillick, McHose & Charles 707 Wilshire Boulevard Los Angeles, California 90017

Dear Mr. Sharp:

This responds to your recent letter to Betsy Harrison of this office concerning the importation of unassembled components for bus chassis from Japan. According to the information in your letter, your client, Isuzu Truck of America, Inc. (IST), is considering importing these unassembled components from Isuzu Motors Limited in japan, and assembling them into bus chassis in the United States. Then, IST would sell the bus chassis to companies which would install bodies on the chassis.

You ask whether your client, IST, would be responsible for assigning a vehicle identification number (VIN) to the bus chassis, which are produced using the imported components. Based on the information given, the answer is yes. Under Federal Motor Vehicle Safety Standard No. 115, Vehicle Identification Number--Basic Requirements, IST would be considered the manufacturer of an incomplete vehicle, because IST would be assembling a frame and chassis structure which would require substantial additional manufacturing operations before it becomes a completed vehicle.

You also state that U.S. Customs may not release the unassembled bus chassis components to IST at the port of entry unless the components bear vehicle identification numbers. We are not aware of any customs regulation which requires a VIN to be affixed to unassembled chassis components.

Sincerely,

Frank Berndt Chief Counsel

December 4, 1984 Betsy Harrison, Esq. Office of the Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street S.W. Washington, D.C. 20590 Re: Vehicle Identification Numbers

Dear Ms. Harrison:

We are attorneys for Isuzu Truck of America, Inc. ("IST"). IST is the distributor of trucks and buses manufactured by Isuzu Motors Limited, a Japanese corporation, in the United States. IST is contemplating importing into the United States unassembled components for bus chassis. IST would assemble the components into bus chassis which would then be sold by IST to companies which would install bodies on the chassis and resell them to end-users.

Your office has previously advised us, on an informal basis, that IST would be the party responsible for placing the required vehicle identification numbers on each bus chassis. We request that you now confirm your opinion in writing. We note that IST is concerned that U.S. Customs may not release the bus chassis components to IST at the port of entry unless the components bear vehicle identifi-cation numbers. We would appreciate your comments on the existence of such a problem.

If you have any questions regarding the foregoing, please do not hesitate to contact the undersigned.

Very truly yours,

LILLICK McHOSE & CHARLES

By:

Keith A. Sharp

KAS:slm

cc: Art Sato Candy Watson