Ms. Susan Gabel
    Rockland Coach Works LLC
    120 Lyons Road
    Mertztown, PA  19539

    Dear Ms. Gabel

    This responds to your December 14, 2004, letter asking whether a "coach" manufactured by your company using a previously used bus chassis requires a new Vehicle Identification Number (VIN) in accordance with 49 CFR Part 565.

    By way of background, the National Highway Traffic Safety Administration (NHTSA) issues Federal motor vehicle safety standards (FMVSS) applicable to new motor vehicles and motor vehicle equipment. Chapter 301 of Title 49 of the United States Code, "Motor Vehicle Safety" (49 U.S.C. §30101 et seq.), establishes a "self-certification" process under which motor vehicle manufacturers are responsible for certifying that their vehicles meet all applicable Federal motor vehicle safety standards.

    NHTSA does not generally regulate rebuilding or re-manufacturing of used motor vehicles. However, if the rebuilding or remanufacturing involves sufficient manufacturing operations and new parts, the vehicle may be considered newly manufactured. This would mean that it would be required to meet all applicable safety standards in effect at the time of rebuilding (re-manufacture), and to be certified as conforming to those standards. Because of the variety of fact situations involved, the agency has found it difficult to establish a general requirement, and it provides opinions on a case-by-case basis.

    In this case, your letter (and the pictures on your web site) demonstrates an extensive manufacturing process, which includes the following:

    1. A used MCI-9 bus is "stripped" completely leaving only the chassis and certain frame components;
    2. Damaged frame components are replaced;
    3. The rear of the vehicle is extended by 5 feet;
    4. The vehicle roof is raised 8 inches;
    5. All exterior body panels are replaced with a custom fiberglass body panels;
    6. The vehicle is equipped with a different (new or remanufactured) engine and transmission;
    7. Wiring, heat, and air components are all replaced;
    8. The vehicle is equipped with a new, custom designed interior featuring living quarters.

    The extent of manufacturing operations and new parts described in your letter indicate that the vehicles in question are newly manufactured motor vehicles. Particularly, we note that vehicles remanufactured by your company feature different, engines, transmissions, and entirely new bodies except for certain frame components. Thus, your company must assign a new VIN to these remanufactured vehicles. We note that these vehicles would be treated as newly manufactured for the purposes of NHTSA’s safety standards and regulations. Among other things, this would mean that your company is required to certify that the vehicles comply with all applicable safety standards in effect as of the date the remanufacturing operations are completed on the vehicles. The information for new vehicle manufacturers is available at our web site at

    I hope you find this information helpful. If you have any other questions, please contact George Feygin of my staff at this address or by phone at (202) 366-2992.


    Jacqueline Glassman
    Chief Counsel