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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.”

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