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NATM, which represents companies that manufacture trailers with gross vehicle weight

ratings (GVWR) of 26,000 lb or less, submitted detailed comments addressing issues unique to

trailer manufacturers. RVIA submitted brief comments on behalf of its trailer manufacturer

members concurring with the NATM comments. NATM generally supported the proposed

changes to Part 565, but raised the following two concerns.

Character Prescriptions as They Relate to Trailers

First, NATM noted that Section 565.6(b) currently applies to “passenger cars and …

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

(10,000 lbs.) or less” insofar as it identifies the characters that must be used in specific positions

of the second section of the VIN (positions 4-8). NATM further noted, “There is, however, no

mention of what characters, alphabetic or numeric, manufacturers of other types of vehicles –

larger trucks, buses, trailers, and motorcycles – are required or permitted to use in those same

positions. By its silence, we assume Section 565.6(b) allows manufacturers of those other types

of vehicles to use either an alphabetic or a numeric character, at their election, in all four of the

first four positions in Section 2 of the VIN, positions 4, 5, 6, and 7. The current regulation goes

on to state: ‘The fifth character [position] may be either alphabetic or numeric.’ It is not clear

whether this statement is intended to govern VIN use only in the three vehicle types specified in

the preceding sentence, namely automobiles, multipurpose passenger vehicles, and light-duty

trucks, or whether it is intended to apply to all motor vehicle types to which Part 565 applies.”

Agency Analysis and Response:

The characters that may be used in a vehicle’s VIN are identified in §565.4(g). These are

the characters that may be used in a VIN unless there are specifications elsewhere in Part 565 as

to the characters that may be used in a particular VIN position.

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