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565 requires the manufacturer to assign a unique VIN to each passenger car, multipurpose

passenger vehicle, truck, bus, trailer (including trailer kit), incomplete vehicle, and motorcycle

that it produces.

One of the original purposes of the VIN system was to enhance public safety by deterring

vehicle theft based on the assumption that drivers of stolen vehicles are more likely to operate

those vehicles unsafely and thus be involved in vehicle crashes. The current 17-character VIN

system embodied in Part 565 continues to serve this purpose and, as stated in Part 565, also

serves “to increase the accuracy and efficiency of vehicle recall campaigns.” Recalls are a

critical tool for correcting safety defects in vehicles. The VIN has also become the key identifier

in data systems that track such things as compliance with federal importation regulations, vehicle

registrations, insurance coverage, and motor vehicle crashes. Entities that today utilize VINs in

data systems include NHTSA, state motor vehicle departments, law enforcement agencies,

insurance companies, organizations involved in motor vehicle research, and manufacturers.

Characters in a VIN are used in one of three ways. Some specific VIN positions

represent a single item of information related to a vehicle. Other groups of VIN positions may

be used individually or in combination to represent information that must be deciphered from a

key that the manufacturer provides to NHTSA as required by Part 565. Utilizing combinations

of at least some VIN positions has been necessary for some vehicles because the amount of

information about a vehicle required by Part 565 to be represented in the first (positions 1-3) and

second (positions 4-8) sections of the VIN in some cases exceeds the number of positions

available in those sections. Finally, the last digits of the VIN are used by manufacturers to

sequentially number groups of similar vehicles that are manufactured. Small annual volume

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