DMV Letterhead

December 13, 1994

Sgt. Jay Enanoria
Hawaii Police Department
349 Kapiolani Street
Hilo, Hawaii 96720-3998

Dear Sgt. Enanoria,

A motorcycle rebuilt or modified with an aftermarket frame is a reconstructed motorcycle. A motorcycle frame manufacturer is not a manufacturer of motorcycles if he only manufactures the frame. He is a motorcycle part manufacturer. Anyone who assembles a complete vehicle is considered to be a manufacturer of vehicles and should be registered with NHTSA. The person who assembles the complete vehicle completes the VIN. That person also certifies that the vehicle meets all of the Federal Motor Vehicle Safety Standards or lists what standards are exempted.

The seventeen digit VIN used by the various frame makers is not acceptable because they do not assemble the complete Vehicle.

All motor vehicles are registered by the frame VIN. Using any other number will cause confusion due to interchangeability of parts (e.g. engine. Transmission, etc.).

Very Truly Yours,
Motor Vehicle Safety Administrator

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