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In addition to commenting that “make” is not a concept used in the trailer industry,

NATM expressed concern that requiring “make” in the second section of the VIN would require

trailer manufacturers to give up what it characterized as an “undesignated” position in the second

section of the VIN to communicate the “make.” That position, NATM said, is currently

generally used in the trailer industry to indicate the GVWR of trailers, which is not an

information item that Part 565 requires for trailers in the second section of the VIN.

Agency Analysis and Response:

The agency’s experience with VINs for trailers generally reflects the NATM comments.

That is, for most trailer manufacturers, the manufacturer’s name has been the equivalent of the

“make” of the trailer, although there are surely instances in which information that is arguably a

“make” has been communicated. In most cases, only the manufacturer’s name has been

communicated in the manufacturer identifier of trailer manufacturers under the current Part 565.

There has been a tacit recognition of what NATM observed, that the manufacturer’s name is the

equivalent of the “make.” The manufacturer’s name has simultaneously fulfilled the requirement

that the manufacturer identifier communicate the manufacturer and the “make.”

The agency has decided not to make an exception for trailers and to include “make” in

the information that must be communicated in, and decipherable from, the second section of the

VIN for trailers.

It seems clear from the NATM comments that generating VINs for trailers is relatively

straightforward in comparison to doing so for other types of vehicles subject to Part 565. By

referring to one of the positions in the second section of the VIN as an “undesignated” position,

NATM suggests that trailer manufacturers use each of the positions in the second section of the

VIN to represent one of the four information items currently listed in Part 565 as having to be

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