Interpretation ID: nht91-2.23

DATE: March 8, 1991

FROM: John E. Calow -- Sr. Safety Engineer, Oshkosh Chassis Division, Oshkosh Truck Corporation, Chassis Division

TO: Dorothy Nacoma -- Chief Council, NHTSA

TITLE: Subject: Supplying additional VIN tag to Final Stage Manufacturer

ATTACHMT: Attached to letter dated 5-20-91 from Paul Jackson Rice to John E. Calow (A37; Std. 115; Part 568)

TEXT:

Oshkosh Chassis Division "OCD" provides chassis to final stage manufacturers.

The final stage manufacturers are requesting OCD to supply a duplicate VIN tag with each vehicle. The additional VIN tag would be supplied in the "chassis document packet." The additional VIN tag would be affixed by the final stage manufacturer, so that it is readable through the vehicle glazing.

There is a possibility of the final stage manufacturer misrepresenting the vehicle by placing the incorrect VIN tag under the vehicle glazing. OCD would have no control of the final stage manufacturer correctly identifying the vehicle.

I would appreciate an answer in writing to the following questions:

-Is it legal for an Incomplete Vehicle Manufacturer to supply the Final Stage Manufacturer with an additional "loose VIN tag"? -What are the legal responsibilities of the Incomplete Vehicle Manufacturer if the incorrect VIN tag is affixed to the vehicle by the Final Stage Manufacturer?

Thank you for your time and cooperation.