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CFR 86.082-2, 2010 model year vehicles may be introduced as early as January 1, 2009 and

production may begin even earlier. Ford also noted that adequate lead time is needed so that

Transport Canada can modify CMVSS 115, which specifies the current Part 565 VIN structure

and content.

Agency Analysis and Response:

The effective date of this final rule is two-fold. It becomes mandatory in one year. That

is, all vehicles manufactured on or after the date one year from today must have VINs that meet

the requirements of this final rule. However, it also applies to vehicles manufactured 180 days

after the date of publication of this rule that have the letter code “A” or “B” in the 10th position

of the VIN. Its application to any particular vehicle based on a manufacturer using the letter “A”

or “B” in the 10th position of the VIN under Part 565 allows for implementation of the new VIN

requirements earlier than 1 year.

The effective date will be different for different manufacturers and different vehicles

manufactured by the same manufacturer because of the different times those vehicles are

manufactured within the same model year. In 1 year VINs will have to conform to the new VIN

requirements of this final rule. Before the 1 year date, a VIN will have to conform to the new

requirements if there is a letter “A” or “B” in the 10th position. Under the current Part 565, a

chart indicates the numbers and letters that are required in the 10th position for particular model

year vehicles. The 2010 model year is the first time a character in this chart, in this case an “A”,

would be repeated in the 10th position, which under the current Part 565 allows for both the

possibility of duplicate VINs and a situation in which a VIN user would not be able to tell

whether a vehicle was manufactured as a 2010 model year vehicle or a model year 30 years

earlier when “A” was last used in the 10th position. Under the amended Part 565, however, an

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