Mr. Tim Czapp

Vehicle Safety and Regulatory Compliance

Fiat Chrysler Automobiles

1000 Chrysler Drive

Auburn Hills, MI 48326

 

Dear Mr. Czapp,

 

This responds to your letter requesting an interpretation as to whether you may locate the vehicle identification number (VIN) plate on a vehicle’s A-pillar.  Based on the information you have provided, the National Highway Traffic Safety Administration (NHTSA) believes motor vehicle manufacturers are able to locate VIN plates on the A-pillar and comply with the agency’s VIN regulations. 

 

In your letter to NHTSA, you stated that Fiat Chrysler Automobiles (Fiat Chrysler) is considering relocating the VIN plate from the vehicle’s dashboard to the interior portion of the vehicle’s A-pillar.  In further correspondence with Ryan Hagen of my staff, you stated that the VIN plate would remain visible from the outside of the vehicle through the glazing, be permanently affixed to the vehicle, and be located on the inside of the passenger compartment.  Further, you stated that the characters of the VIN would essentially be rotated 90° counterclockwise from a traditional VIN orientation and meet the height and character regulations.  You also included an illustration of the new VIN location relative to present VIN locations. 

 

By way of background information, under the National Traffic and Motor Vehicle Safety Act (Vehicle Safety Act, 49 U.S.C.

§§ 30101 et seq.) NHTSA has the authority to issue Federal motor vehicle safety standards and other regulations for new

motor vehicles.  NHTSA does not provide approvals of any motor vehicle.  Under the Vehicle Safety Act, it is a

manufacturer’s responsibility to determine whether a motor vehicle complies with all applicable regulations, and to certify

its products in accordance with that determination.  The following interpretation represents the agency’s opinion based on

the information provided in your letter.

 

NHTSA requires vehicles to be marked with VINs to simplify vehicle identification information retrieval and to increase the accuracy and efficiency of vehicle recall campaigns.  The agency’s regulations at 49 CFR Part 565 set forth the general requirements for VINs.  Of particular relevance to the present question, 49 CFR 565.13(e) states that “[t]he VIN of each vehicle shall appear clearly and indelibly upon either a part of the vehicle, other than the glazing, that is not designed to be removed except for repair or upon a separate plate or label that is permanently affixed to such a part.”  Further, 49 CFR 565.13(f) states that passenger cars, multipurposes passenger vehicles, low speed vehicles, and trucks with a GVWR of 4536 kg or less must be located within the passenger compartment.  Moroever, “[i]t shall be readable, without moving any part of the vehicle, through the vehicle glazing under daylight conditions by an observer… whose eye-point is located outside the vehicle adjacent to the left windshield pillar…” 

 

Based on the details you have provided the agency, NHTSA believes your proposed VIN plate location would not prevent the plate from complying with 49 CFR Part 565.  Despite being moved to a novel location (the A-pillar), a VIN plate located there could meet NHTSA’s VIN regulations, assuming it complied with the remainder of the agency’s VIN regulations (e.g. minimum character height, capital, sans serif characters, etc.).  

 

One additional note—because VINs are often used by law enforcement officials, we recommend notifying the relevant Federal, state, and local law enforcement agencies and others who frequently use VINs of this VIN plate location change. 

 

I hope you find this information helpful.  If you have further questions, please contact Ryan Hagen of my staff at (202) 366-2992. 

 

                                                                                    Sincerely,

 

 

 

                                                                                    Paul A. Hemmersbaugh

                                                                                    Chief Counsel 

Dated: 9/21/16

Ref: Part 565