The Motor Vehicle Safety Regulations (MVSR) were amended in February 2020 as part of the Regulations Amending Certain Regulations Made Under the Motor Vehicle Safety Act (National Safety Marks and Importation): SOR/2020-22, 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 include vehicles that are designed to travel with not more than four wheels in contact with the ground and that are not designed for use on public roads.
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 Motor Vehicle Safety Act ensures that, among other things, these vehicles fall under the safety recall regime. With these changes, the vehicles are now required to bear a Vehicle Identification Number.
On this page
- Vehicle Identification Number (VIN)
- Inadvertent trade issue
- Coming into force
- We want to hear from you
- Related links
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 the manufacturer, year of production, place of production and vehicle characteristics. It is a vehicle’s fingerprint and is essential for vehicle registration and to help target individual vehicles to address issues such as safety recalls. VIN is defined in section 2 of the MVSR as “a number consisting of Arabic numerals, roman letters, or both that the manufacturer assigns to the vehicle for identification purposes”.
In order to formulate a VIN that complies to Canadian requirements (included in Canadian Motor Vehicle Safety Standard (CMVSS) 115), a set of characters that uniquely identify the manufacturer and the prescribed class of vehicle must be used. These characters are generally referred to as a World Manufacturer Identifier (WMI) code. In Canada, the manufacturer must apply to the Canadian Vehicle Manufacturer’s Association (CVMA) to assign a unique WMI to the manufacturer, which they will include as part of the 17-character alphanumeric VIN on the vehicle.
In the United States (U.S.), SAE International (SAE) is contracted by the National Highway Traffic Safety Administration (NHTSA), to assign the WMI. However, due to the limited supply of WMIs, the NHTSA provided clarification to SAE regarding the types of vehicles to be included in the VIN system. The SAE stopped issuing new WMIs to off-road vehicle manufacturers in 2005 to limit the use of VINs on vehicles which do not require them in the U.S. (unlike in Canada where VINs are required on such vehicles). Manufacturers who received a WMI prior to 2005 can continue to use it to generate VINs. To meet state requirements for identification numbers, the SAE developed the Product Identification Number (PIN) system to replace VINs for off-road vehicle manufacturers that could no longer obtain a WMI from the SAE. Since this directive by NHTSA, manufacturers of off-road vehicles in the U.S., that didn’t have a WMI prior to 2005, have been using PINs for their vehicles.
The PIN is similar to VIN in that it is used to uniquely identify a vehicle and information related to its manufacturing, including where it was manufactured. Both VIN and PIN consist of 17-character alphanumerical codes, used as unique vehicle identifiers. The difference lies in the 9th character of these codes where a VIN uses a numerical check digit in this position, while a PIN uses a check letter instead. This, in turn, makes the PIN system incompatible with the requirements of CMVSS 115 - Vehicle Identification Number.
Inadvertent trade issue
While the requirements of CMVSS 115 do not currently pose a problem for Canadian manufacturers, who can obtain a WMI from the CVMA, some foreign manufacturers of off-road vehicles are unable to obtain a WMI from the designated authority in their jurisdiction. As such, an unintended consequence of the change, which came into force in February 2021, is that some foreign-manufactured restricted-use vehicles and snowmobiles cannot comply with CMVSS 115.
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 located in the U.S. 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. It also offers no solution for vehicles manufactured outside the U.S.
In addition, snowmobiles are also considered as off-road vehicles in the U.S. and are allowed to have either a VIN or PIN affixed as required in Snowmobile Safety and Certification Committee (SSCC) 53 – Snowmobile Identification Numbers Footnote 1, while, in Canada, a snowmobile can only bear a VIN due to specification in CMVSS 1201 – Snowmobiles. Snowmobile manufacturers may therefore also have difficulties acquiring a new WMI from the SAE. Moreover, snowmobiles sold at the retail level in the U.S. may be imported in Canada. Expanding the allowance for the use of a PIN for snowmobiles will provide manufacturers who are not able to get a WMI with greater flexibility to make vehicles for the Canadian market.
Past consultation
Transport Canada previously held a consultation on allowing PINs from November 17th, 2021, to January 7th, 2022. Comments were received from five stakeholders. All the feedback received was supportive of the initiative. Some comments identified that the use of a VIN was burdensome to clients and manufacturers as well as impeding on cross-border trade; while other comments suggested that the “VIN only” Canadian policy isn’t beneficial to any party. Transport Canada also received a comment indicating that the PIN and VIN systems should be easily distinguishable from one another to avoid any confusion, particularly for consumers, and that this could be another way of distinguishing on and off-road vehicles. Generally, the comments indicated that allowing PINs would greatly alleviate administrative procedures and simplify importations. Lastly, stakeholders insisted that the allowance for a PIN should be an alternative to the VIN which would still be accepted; this would be the approach taken by Transport Canada in amending the MVSR.
Transport Canada is therefore considering an amendment to the regulations that would provide companies the option to use the PIN system as an alternative to the VIN for restricted-use vehicles and snowmobiles. This would remove existing barriers to trade and allow for the importation of Canadian-compliant vehicles manufactured outside Canada. For vehicle manufactured in the U.S., it would also reduce the burden on the SAE and U.S. manufacturers, remove ambiguities of vehicle origin, and keep the Canadian stock of WMIs available.
Recall Information
On June 17th, 2023, the Regulations Amending Certain Regulations Made Under the Motor Vehicle Safety Act (Recall Information) was published in the Canada Gazette Part I with the purpose of requiring information regarding safety recalls to be readily available for vehicle owners through the companies’ online website. Companies would need to provide the safety recall information on their website, or if designated by the Minister, they would need to provide a VIN lookup tool to obtain safety recall information associated to a specific VIN. The intent of the allowance of a PIN would be to authorize manufacturers to use this identification system in place of a VIN for certain prescribed classes of vehicles. It is Transport Canada’s objective that should a company decide to use the PIN system instead of the VIN, the company would be required to meet the same website requirements for safety recalls as those with a VIN.
Coming into force
Transport Canada is holding a second informal consultation, as part of a pre-regulatory process, on the subject to assess if stakeholders still support the proposed allowance of PIN for the prescribed class of restricted-use vehicles and for snowmobiles, as an alternative to the VIN. Since this change would create an alternative to the existing regulations, Transport Canada intends to propose that these amendments be published directly in the Canada Gazette, Part II. The requirements would come into force immediately once they’re published in the Canada Gazette, Part II.
We want to hear from you
- What are your thoughts on allowing restricted-use vehicles and snowmobiles to be identified through the use of either a PIN or a VIN?
- How, if at all, should TC address distinguishing between the use of a PIN or a VIN on the vehicle compliance label?
- Are any additional costs anticipated with the allowance of PIN?
- Do stakeholders support Transport Canada’s plan to make these changes by publishing the amendment directly in the Canada Gazette Part II with the coming into force of the amendment immediately upon publication?