Interpretation ID: nht80-2.17

DATE: 04/24/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: BMW of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Karl-Heinz Ziwica Manager, Safety & Emission Control Engineering BMW of North America, Inc. Montvale, New Jersey 07645

Dear Mr. Ziwica:

This responds to your letter of March 12, 1980. You asked whether, in the case of motorcycles, the appearance of the vehicle identification number (VIN) on the certification label required by 49 CFR Part 567 satisfies the requirements of S4.3 of Safety Standard No. 115 (49 CFR 571.115). The answer is yes. The Part 567 certification label meets note that, in order to satisfy Safety Standard No. 115, the VIN on the certification label must meet the style requirements of S4.3.1.

Sincerely,

Frank Berndt Chief Counsel

March 12, 1980

Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation 400 - 7th Street S.W. Washington DC 20590

RE: Request for Interpretation FMVSS 115, Vehicle Identification Number

Dear Sir

We request confirmation, that in the case of motorcycles, it would be permissible to simultaneously comply with FMVSS 115, S 4.3, and Part 567.4 (a), (b), (e) and (g)(6), which describe the method of affixing a VIN to a motorcycle in substantially the same language that is not mutually exclusive. It is our understanding that the certification label, which must bear the VIN, if applied in the form of a permanent label that cannot be removed without destruction, to the chassis of a motorcycle as close as practicable to the intersection of the steering post with the handle bars, would fulfill the requirements of both Part 567 and FMVSS 115.

Very truly yours

Karl-Heinz Ziwica, Manager Safety & Emission Control Engineering

KHZ/jps