Interpretation ID: 2518y

Mr. Pat Crahan
Director, Government Relations
U-Haul International
2727 North Central Avenue
P. O. Box 21502
Phoenix, Arizona 85036-1502

Dear Mr. Crahan:

Thank you for your letter to Dr. August Burgett of this agency, seeking an interpretation of Standard No. 115, Vehicle Identification Number -- Basic Requirements (49 CFR 571.115). I apologize for the delay in this response. Specifically, you stated that U-Haul manufactures its trailers itself and never sells those trailers to any other party. You asked if Standard No. 115 requires trailers that are used exclusively by the party that manufactures them to be identified with a vehicle identification number (VIN). The answer to your question is yes.

S2 of Standard No. 115 specifies that the standard applies to trailers, and makes no exception for trailers that are used exclusively by the manufacturer. S4.1 of Standard No. 115 provides that: "Each vehicle manufactured in one stage shall have a VIN that is assigned by the manufacturer." Again, no exceptions are set forth for vehicles that will be used exclusively by the manufacturer. Because those regulatory provisions do not include any special exceptions, every new trailer must have a VIN, irrespective of whether the trailer will only be used by the same party that manufactured it.

I hope this information is useful. If you have any further questions or need any additional information about this topic, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel ref:115 d:7/9/90