Vermont, offered general support for the rulemaking and made suggestions concerning
information that the VIN should communicate.
Specific suggestions, exceptions, and concerns expressed by those offering general
support for the proposed changes to Part 565 are discussed below under the relevant heading.
Large Manufacturer Threshold
The Alliance and Prevost commented directly on this subject. The Alliance specifically
supported the proposed change that would require a manufacturer to make 1000 vehicles a year
rather than the current 500 before a manufacturer will be considered a large manufacturer and be
required to be issued and use a large manufacturer identifier. Prevost expressed a concern about
manufacturers of buses with a GVWR greater than 4,536 kg (10,000 lb), stating that production
of these manufacturers may vary significantly so the threshold between small and large
manufacturer should be smaller than 500 with the possibility to use either a 3 or a 6 character
WMI up to 1000.
Alphabetic and Numeric Characters in Second Section of VIN
The Alliance specifically supported the proposal to allow the VINs of passenger cars and
multipurpose passenger vehicles and trucks with a gross vehicle weight rating of 4536 kg
(10,000 lb) or less to use either alphabetic or numeric characters in positions 4, 5 and 6, as
opposed to only alphabetic characters in positions 4 and 5 and numeric characters in position 6.
As noted above, some manufacturers did not agree with the proposed changes for position 7 of
the VIN. AIAM objected to a requirement that “all restraint devices and their location” be
decipherable from the VIN.