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The NATM’s interpretation of the current version of Part 565.6(b) is correct. The

specifications in the current version of this section as to the type of characters that must appear in

specific positions of the second section of the VIN apply only to the vehicles cited - passenger

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

kg (10,000 lb) or less - not larger trucks, buses, trailers, and motorcycles. Therefore, the current

regulation allows manufacturers of larger trucks, buses, trailers, and motorcycles to use either an

alphabetic or a numeric character in all four of the first four positions in the second section of the

VIN, positions 4, 5, 6, and 7. Position 8 under the current regulation may be either an alphabetic

or numeric character for any type of vehicle. Nothing will change for these vehicles under this

final rule. In this final rule, only position 7 will be limited to an alphabetic character for

passenger cars, multipurpose passenger vehicles and trucks with a gross vehicle weight rating of

4536 kg (10,000 lb) or less. All other positions in the second section of the VIN will be allowed

to have either alphabetic or numeric characters no matter what type of vehicle is involved and

position 7 may be alphabetic or numeric for larger trucks, buses, trailers, and motorcycles.

Trailer “Make”

NATM’s second concern was over NHTSA’s intention to move vehicle “make” from

being a characteristic that needs to be communicated in the manufacturer identifier to a

characteristic that needs to be communicated in the second section of the VIN. “Unlike

automobiles, multipurpose passenger vehicles, and light-duty trucks, light-duty and medium-duty

trailers generally do not have separately assigned or designated ‘makes,’ much less undergo

frequent changes in ‘makes,’” NATM said. The NATM further stated that under the current

regulation, the company name in the manufacturer identifier is, in essence, the make of the

trailer.

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