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established by today’s final rule. While having the option of either an alphabetic or numeric

character in position 7 might “minimize the cost impact” on manufacturers as BMW suggests, it

would also very likely add costs to other users of the VIN system and not be as efficient as

having position 7 clearly indicate the 30 year period in which a vehicle was manufactured. The

agency is therefore adopting the proposal in the NPRM to require that only an alphabetic

character be allowed in VIN position 7 for passenger cars and multipurpose passenger vehicles

and trucks with a gross vehicle weight rating of 4536 kg. (10,000 lbs.) or less under the revised

Part 565.

The agency agrees with the Alliance, GM and Prevost that a footnote to Table VII will

further clarify the purpose of position 7 being an alphabetic character. The agency is therefore

adding a footnote to Table VII, but is adopting language different from that proposed by the

Alliance and GM to both further clarify the role of VIN position 7 and to make clear, as

suggested by Prevost, that the requirement for an alphabetic character in position 7 applies only

to passenger cars and multipurpose passenger vehicles and trucks with a gross vehicle weight

rating of 4536 kg (10,000 lb) or less. The footnote will now read, “For passenger cars, and for

multipurpose passenger vehicles and trucks with a gross vehicle weight rating of 4536 kg

(10,000 lb) or less, if position 7 is numeric, the Model Year in position 10 of the VIN refers to a

year in the range 1980-2009. If position 7 is alphabetic, the Model Year in Position 10 of the

VIN refers to a year in the range 2010-2039.”

5. Off Road Vehicles

Comment:

NACAA said the VIN system should be extended to “nonroad vehicles (primarily those

for recreational use).”

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