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The agency acknowledges that the additional information requirements recommended in

the comments, such as those relating to California emission certification, reflect the fact that

there has been little change over the decades in the information that must be conveyed by a VIN

despite the development of new circumstances that may lend themselves to the inclusion of new

or different information. As such, the agency plans to initiate a separate comprehensive review

focused on the information requirements of the VIN system. This will address whether those

requirements should be changed, and, if so, how those changes should be made.

3. All Restraint Devices and Their Location

Comments:

Several comments were received concerning the proposal to change language in Table 1

of 49 CFR 565.6(b) relating to the restraint system information required to be communicated in

the VIN of passenger cars. The relevant language currently reads, “Passenger car: line, series,

body type, engine type and restraint system type.” The replacement language proposed by the

petitioner and included in the NPRM reads, “Passenger car: Make, line, series, body type, engine

type, and all restraint devices and their location.”

The agency also requested “comments on whether this information should be required for

all passenger vehicles, not just passenger cars.”

The Alliance opposed this proposed change and suggested that the original language be

retained. It said the proposed language would create an “unnecessary and unjustified burden on

manufacturers” because each running change relating to a vehicle’s restraint system could

require a new VIN.

The AIAM also opposed the proposed change, on the basis that evolving combinations of

restraint devices could “require development of a complex coding scheme which may ultimately

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