Ferrari stated, “Regarding the possibility to distribute old manufacturer identifiers no
longer in use, we believe that they should be retained by the same manufacturer to avoid possible
confusion in case they are given to other manufacturers.”
Agency Analysis and Response:
The agency does not see a need to take any action at this time beyond adopting the
changes discussed in this final rule. As previously noted, vehicle make has been moved from the
manufacturer identifier to the second section of the VIN. This should substantially reduce the
need to issue new large manufacturer WMIs, thus extending the remaining supply of 400-450 of
these manufacturer identifiers.
In addition, the agency, through its contract with SAE for the issuance of manufacturer
identifiers, has begun the process of identifying companies with large manufacturer identifiers
that are no longer in business so that those identifiers may be returned to the system. The agency
is also identifying companies that were issued large manufacturer identifiers that, through
publicly available data, the agency knows do not produce more than 500 vehicles a year, the
current threshold for being considered a large manufacturer, or 1,000 vehicles a year, the
threshold in this final rule, under Part 565. The agency anticipates that a number of large
manufacturer identifiers will be returned to the system as a result of this process as well.
9. Posident Typeface
While NHTSA did not propose any specific action relating to the “positive identification
style”/“posident” typeface, the subject was addressed in the NPRM and two commenters
specifically commented on it.