Interpretation ID: nht90-3.8

TYPE: Interpretation-NHTSA

DATE: July 9, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Pat Crahan -- Director, Government Relations, U-Haul International

TITLE: None

ATTACHMT: Letter dated 1-26-90 to A. L. Burgett from Pat Crahan attached; OCC 4404 TEXT:

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 S571.115). I apologize for the delay in this response. Specifically, you stated th at 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 nu mber (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 t hat 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, irres pective 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.

LPDS 1989