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communicated in, and decipherable from, the second section of the VIN. This approach leaves

one position of the VIN’s second section unused or “undesignated” as the NATM’s comments

state. According to NATM, this unused position is widely used in the trailer manufacturing

industry to designate GVWR. The NATM comments suggest that trailer manufacturers fear that

if they are required to communicate a vehicle’s make in the second section of the VIN, even

though the manufacturer name is the make for most trailer manufacturers, they will have to use

the position now widely used for GVWR to indicate the manufacturer’s name for a second time

(the manufacturer’s name will continue to be required in the manufacturer identifier).

The agency notes that one option available to trailer manufacturers whose manufacturer

name is the same as the make is to continue to use a character in the position that is now, by

practice, used for GVWR. In the information for deciphering the VIN submitted to NHTSA

under § 565.7(c) trailer manufacturers can simply indicate that if any character appears in that

position, then the make name is the same as the manufacturer name.

It should be noted that if a trailer manufacturer produces 33 or fewer variations of trailers

(i.e. combinations of make, type of trailer, body type, length and axle configuration – the

information items required for trailers in the second section of the VIN as revised), this

information could be communicated by a single character in one position of the second section of

the VIN. What that single character refers to would simply have to be indicated in the

information provided to NHTSA by the manufacturer under §565.7(c). In fact, a trailer

manufacturer could communicate up to 132 different variations in the trailers it manufactures

and use only four of the five positions in the VIN’s second section by taking full advantage of

the 33 characters available for each of those positions and submitting to NHTSA a full and

complete description of what a given character means if it appears in a given position. A “B” in

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