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change in a vehicle’s restraint system occurs, a company could retain the VINs of the vehicles

involved and provide NHTSA with revised VIN deciphering information as provided in 49 Part

565.7(c). In such a case, vehicles numbered sequentially above a certain number in the last

digits of the fourth section of the VIN would have the revised restraints devices and locations,

which could be indicated in the company’s amended deciphering information.

The agency agrees with Advocates that there is value in having the VINs of certain

vehicles in addition to passenger cars communicate the type and location of the restraint devices

with which those vehicles are equipped . The agency is requiring the VINs of passenger cars,

multipurpose vehicles, and trucks with a gross vehicle weight rating of 4,536 kilograms (10,000

pounds) or less to communicate that information.

4. VIN Position 7


The NPRM proposed that for passenger cars and multipurpose passenger vehicles and

trucks with a gross vehicle weight rating of 4536 kg (10,000 lb) or less the seventh position of

the VIN be changed from a numeric character to an alphabetic character.

Daimler and BMW asked that the seventh position be either numeric or alphabetic, with

BMW indicating this would “minimize the cost impact” and achieve the same goal. Ferrari

called the proposed change for position 7 “acceptable,” but asked why position 7 could not be

either numeric or alphabetic.

Daimler also asked that the manufacturer be allowed to choose “one of the five positions

to be changed from alphabetic to numeric or vice versa.” (Daimler did not specify the five

characters to which it was referring. The agency assumes the company was referring to VIN

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