Background: Product Identification Numbers for restricted-use vehicles

The Motor Vehicle Safety Regulations (MVSR) were amended in February 2020 which, among other changes, made amendments to rename the prescribed class “restricted-use motorcycle” to “restricted-use vehicle” in order to better represent the types of vehicles included under the expanded definition of the prescribed class. The definition of “restricted-use vehicle” was expanded to encompass all vehicles that are designed to travel with not more than four wheels in contact with the ground and which are not designed for use on public roads. A restricted-use vehicle with a maximum attainable speed of less than 32 km/h in 1.6 km (1 mile) is not considered as part of the prescribed class.

The expanded definition for the prescribed class “restricted-use vehicle” encompasses vehicles not previously captured in the MVSR, such as four-wheeled off-road utility vehicles. Prior to these amendments, these vehicles were not regulated and their inclusion in the scheme under the Act ensures that, among other things, these vehicles fall under the defect and recall regime. With these changes, the vehicles are also required to be fitted with a VIN. The definition also creates better alignment between the Canadian regulations and those of the United States where lower-speed off-road vehicles, such as power-assisted bicycles, scooters and electric or low-speed all-terrain vehicles are not federally regulated by the National Highway Traffic Safety Administration (NHTSA) but by the Consumer Product Safety Commission. In Canada, these vehicles fall under provincial or territorial jurisdictions. The provinces and territories have the freedom to decide whether to permit the use of these vehicles in their jurisdictions and under what conditions.

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Vehicle Identification Number (VIN)

Since 1981, global automotive manufacturers have used a numbering system called a VIN that uniquely describes a vehicle. This number provides a coded description of the vehicle including: manufacturer, year of production, place of production and vehicle characteristics. It is a vehicle’s fingerprint and helps to protect consumers by ensuring that all vehicles are manufactured in compliance with the Motor Vehicle Safety Act.

Prior to manufacturing a product/vehicle for on-road use, a World Manufacturer Identification Code (WMI) is required by the manufacturer. In Canada, the manufacturer must first contact Transport Canada to obtain an application package and review documentation before authourising the Canadian Vehicle Manufacturer’s Association (CVMA) to issue a WMI. The CVMA will process the application and the manufacturer will be issued a WMI code which they will include as part of the 17 alphanumeric digit VIN.

In the U.S., SAE International is contracted by the National Highway Traffic Safety Administration (NHTSA), to assign the WMI. However, due to the limited supply of WMIs, NHTSA directed the SAE to cease issuing new WMIs to off-road vehicle manufacturers by 2005 to limit the use of VINs on vehicles which do not require them in the U.S. To meet state requirements for identification numbers, the SAE developed the Product Identification Number (PIN) system to replace VINs in these types of vehicles. The PINs are similar to VINs, and use a World Manufacturer Code (WMC) to generate a 17-digit PIN. Since this directive by NHTSA, manufacturers of off-road vehicles in the U.S. have been using PINs for their vehicles.

Inadvertent trade issue

While the VIN requirement does not pose a problem for Canadian manufacturers which can obtain a WMI from the CVMA, U.S. manufacturers are unable to obtain a WMI from SAE. As such, an unintended consequence of the change which came into force in February 2021 is that some restricted-use vehicles manufactured in the U.S. cannot be imported into Canada.

Upon identifying this issue, and following discussions with NHTSA, Transport Canada and the SAE, a temporary solution was implemented whereby the SAE could allocate a Canadian WMI to affected manufacturers so they can create a valid VIN for these specific vehicles. Although this temporary solution is in place, the situation is not ideal as the Canadian WMI incorrectly indicates that the vehicle was manufactured in Canada, therefore the issue must be corrected for the long-term.

Transport Canada would therefore like to amend the regulations to allow restricted-use vehicles to use the PIN system as an alternative to the VIN. This would reduce the burden on the SAE, U.S. manufacturers, remove ambiguities of vehicle origin and keep the Canadian stock of WMIs available, all while permitting the import of restricted-use vehicles manufactured in the U.S..

Coming into force

This is an informal consultation which is part of a pre-regulatory process. Since this change would create an alternative to the existing regulations, the amendments may be published directly in the Canada Gazette, Part II. The requirements would come into force once they’re published in the Canada Gazette, Part II.

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