threshold between low-volume manufacturers and high-volume manufacturers, such an action
would jeopardize the limited supply of manufacturer identifiers for high-volume manufacturers,
which was one of the driving concerns for the petition that initiated this rulemaking and for the
agency’s proceeding with this rulemaking. If, after the implementation of this final rule, there
continue to be manufacturers that vacillate between low-volume and high-volume status, the best
place to address this will be in the administration of the VIN system. In this way, NHTSA can
better monitor the supply of large manufacturer identifiers and be sure that they are issued only
in situations where it is appropriate to do so.
14. Effective Date of the Rule
There were numerous comments concerning the effective date of the final rule,
particularly the need for the final rule to be implemented quickly with a clear indication that it
applies to all model year 2010 vehicles. One commenter said the revised Part 565 should apply
to model year 2010 vehicles regardless of when they are manufactured.
The Alliance, AIAM, and Ferrari said the rule should begin with 2010 model year. The
Alliance noted, “Some manufacturers are already approaching the deadline to implement
changes to VIN structure for model year 2010.” It suggested that there be a period, applicable to
the 2009 model year, during which a manufacturer would be allowed to comply with either the
old or new system. TMA also urged quick adoption.
NICB provided detailed comments that focused entirely on the issue of effective date. It
said the changes to the VIN system are needed “urgently” and that a failure to implement the
new structure within the next year would lead to “serious consequences.”