Referring to a numbering system for off-road vehicles named, “PIN: Product
Identification Number System for Off-Road Recreation Vehicles,” NYDMV noted that identifiers
under this system will always differ from VINs in the ninth position. A VIN will contain either a
number or an X. A PIN will contain a letter and never an X. NYDMV suggested language for
Part 565 that would prohibit VINs from duplicating PINs for off-road vehicles.
Agency Analysis and Response:
NHTSA has authority to regulate only vehicles that are manufactured primarily for use
on public streets, roads, and highways. Jurisdiction to regulate vehicles of the type discussed by
NACAA rests with the U.S. Consumer Product Safety Commission, which at this time does not
have a system in place to provide identifiers for off-road vehicles.
As indicated by the NYDMV, a voluntary system has been created and is operating to
address the need for identifiers for off-road vehicles. That system is administered by SAE
International, the same organization that administers the VIN system.
NHTSA does not have the authority to extend the VIN system to off-road vehicles. It
therefore did not address the issue in the NPRM and is not making this suggested change in this
NHTSA is also not including language in Part 565 to prohibit a VIN from duplicating a
PIN as suggested by NYDMV. We do not regulate PINs. Additionally, the agency believes that
if, as the NYDMV indicates, a PIN has an alphabetic character and never an X in its ninth
position, a VIN should never duplicate a PIN. This is because a VIN is required to have either a
numeric character or an X in that position.