Vol. 142, No. 31 — August 2, 2008

Regulations Amending the Motor Vehicle Safety Regulations (Vehicle Identification Number)

Statutory authority

Motor Vehicle Safety Act

Sponsoring department

Department of Transport

(This statement is not part of the Regulations.)

Issue and objectives

This proposal would amend the Canadian requirements for Vehicle Identification Numbers (VIN) in section 115 of Schedule IV of the Motor Vehicle Safety Regulations (MVSR). This amendment is needed to ensure that each vehicle sold in Canada will have a unique identification number. The current identification system has a usable span of 30 years, within which each vehicle produced has a unique 17-digit VIN. This proposal will allow the 17-digit VIN to continue to be unique for each vehicle produced within a 60-year period of time.

Description and rationale

Every vehicle manufactured or imported for sale in Canada is required to have a 17-digit VIN. The VIN is an alphanumeric code that provides information regarding: manufacturer, year of production, make, model and several technical details that uniquely identify a specific vehicle. The VIN is needed to facilitate vehicle identification for safety research and for vehicle recall campaigns. The VIN is also used by provincial and territorial jurisdictions for registration purposes. Several other entities such as vehicle distributors, financial institutions, insurance companies and police departments use VIN for warranty validation, insurance claim verification, recall campaigns and vehicle theft investigation.

This proposal would require that the VIN of any two vehicles manufactured within a 60-year period not be identical. The present system is only capable of handling a 30-year span. To effect the change, the information regarding the make of vehicle would be moved from the first three positions to positions four through eight. The characters in positions four through eight would be alphabetic or numeric. For specific classes of vehicles, position seven would be required to be alphabetic. This would offer more flexibility to manufacturers to encode the mandatory information and allow them to uniquely identify vehicles for a 60-year period. A low-volume manufacturer would be defined as a manufacturer producing up to 1 000 vehicles yearly, and identified by the number nine in the third position, in conjunction with related information in positions one, two and twelve to fourteen. It is proposed that this amendment would apply to vehicles built on or after October 27, 2008, having a model year of 2010 or 2011, and to vehicles having a later model year. Those vehicles having a model year of 2009 or less and those vehicles having a model year of 2010 or 2011, if they are built before October 27, 2008, would be required to comply with the existing VIN system.

This proposed amendment would align the Canadian requirements regarding the VIN system with recent requirements introduced in the United States. Due to the free movement of goods and the open transportation system between Canada and the United States, it is important that the VIN systems be aligned.

Under the Department’s Strategic Environmental Assessment policy, a preliminary evaluation of the possible effects of this proposed amendment was done. It was determined that this proposed amendment would have no impact on the environment.

Consultation

As part of its consultation process, the Department of Transport informs the automotive industry, public safety organizations and the general public when changes are planned to the MVSR. This gives them the opportunity to comment on these changes by letter or email. The need to amend the VIN system has been published in the Department’s Regulatory Plan and extensive negotiations have taken place over the past several years to develop a VIN system that meets the needs of all stakeholders, including the manufacturers and the provincial and territorial governments.

As the provinces and territories use the VIN to identify vehicles in their vehicle registration databases, it is imperative that changes to it align with their current systems. The Department has been working with the Canadian Council of Motor Transport Administrators to ensure that all concerns have been addressed.

Manufacturers are supportive of this amendment as they require a unique numbering system that is consistent across Canada and the United States and is recognized throughout the world. The manufacturers have written to the Department in March 2008, expressing their concern that this amendment be aligned with the final regulatory requirements of the United States and also, that it be completed urgently as the new system will be needed for the 2010 model year vehicles, which could be produced as early as January 2009.

Implementation, enforcement and service standards

Motor vehicle manufacturers and importers are responsible for ensuring that their products conform to the requirements of the MVSR. The Department of Transport monitors self-certification programs of manufacturers and importers by reviewing their test documentation, inspecting vehicles, and testing vehicles obtained in the open market. In addition, when a defect in a vehicle or equipment is identified, the manufacturer or importer must issue a Notice of Defect to the owners and to the Minister of Transport, Infrastructures and Communities. If a vehicle does not comply with a Canadian safety standard, the manufacturer or importer is liable to prosecution and, if found guilty, may be fined as prescribed in the Motor Vehicle Safety Act.

Marcin Gorzkowski, P.Eng.
Senior Regulatory Development Officer
Road Safety and Motor Vehicle Regulation Directorate
Transport Canada
275 Slater Street, 17th Floor
Ottawa, Ontario
K1A 0N5
Email: gorzkowm@tc.gc.ca

Please note: It is important that your submission be provided to the attention of the person noted above before the closing date. Submissions not sent directly to the person noted may not be considered as part of this regulatory proposal. Individual responses to your submission will not be sent. Any subsequent final Regulations that are published in the Canada Gazette, Part II would contain any changes that are made, along with a summary of the relevant comments received. Please indicate in your submission if you do not wish to be identified or if you do not wish to have your comments published in the Canada Gazette, Part II.