So I challenge a Spartan owner to find the regulation and post the reference for the VIN requirement.
Best way to squash internet rumors is finding the actual info.
This is from my post "over there"
This is going to be long. I made some very clear statements, but in doing so in such a short way, it allows for gaps.
The pertinent question(s):
Pursuant to 49 CFR Part 565 (Vehicle Identification Number Requirements) and 49 CFR Part 567 (Certification):
1. Does Spartan have to stamp the VIN on the chassis frame?
2. Does Newmar as a final stage builder have ti verify the VIN has been stamped on the chassis frame?
3. What are the penalties if no VIN was stamped or affixed to the chassis frame?
ANSWERS:
1. Does Spartan have to stamp the VIN on the chassis frame?
Yes.
• 49 CFR § 565.13(e) requires that the VIN appear “clearly and indelibly upon a part of the vehicle … that is not designed to be removed except for repair, or upon a separate plate or label that is permanently affixed to such a part.”
• In practice, for an incomplete vehicle chassis (like those built by Spartan or Freightliner Custom Chassis), the industry standard and NHTSA expectation is that the VIN is stamped or embossed on the chassis frame rail.
• This is considered the primary, non-removable VIN marking that law enforcement and DMVs use to establish the legal identity of the vehicle.
So, Spartan as the incomplete vehicle manufacturer is responsible for stamping the VIN on the chassis rail (or another non-removable structural part) and also placing the certification label with the VIN per Part 567.
2. Does Newmar, as a final-stage builder, have to verify the VIN has been stamped on the chassis frame?
Yes, indirectly.
• Under 49 CFR Part 567 (Certification of Vehicles), the final-stage manufacturer (Newmar in your example) must ensure that the completed vehicle still conforms to all applicable Federal requirements, including the VIN rules in Part 565.
• Newmar does not have to physically stamp or restamp the VIN (that’s Spartan’s job).
• But Newmar is responsible for verifying that the VIN on the chassis and the VIN on the certification label are present and consistent. If they complete and certify a vehicle without a valid VIN, they would also be in violation.
Think of it this way: Spartan creates the VIN, stamps it, and applies its incomplete-vehicle label. Newmar must carry that VIN forward and ensure the finished coach has a compliant certification label tied to the same VIN.
3. What are the penalties if no VIN was stamped or affixed to the chassis frame?
Severe.
• Under 49 U.S.C. § 30165, NHTSA can assess civil penalties for each violation of the VIN and certification requirements.
• As of 2023, the penalty is up to $26,315 per violation, per vehicle, capped at over $130 million per related series of violations.
• Beyond civil fines, a missing or fraudulent VIN can trigger:
• Vehicle recall obligations (manufacturer has to fix or repurchase the affected vehicles).
• Seizure of vehicles by law enforcement (since they cannot be legally registered without a valid VIN).
• Criminal exposure if the omission was intentional or tied to fraud (18 U.S.C. § 511 prohibits VIN tampering or removal).
In summary:
• Spartan must stamp the VIN on the chassis frame and affix its certification label.
• Newmar must verify and carry that VIN forward when certifying the final-stage vehicle.
• Failure to stamp or affix a VIN risks NHTSA civil penalties, recalls, registration problems, and possible criminal issues if intent to misrepresent is proven.
PENALTIES:
Exact Statutory Language — 49 U.S.C. § 30165
The law states:
• A person who violates any regulation under various sections of Title 49 — including VIN requirements — is liable for a civil penalty of up to $21,000 for each violation, with each vehicle counted separately. The maximum total for a related series of violations is $105,000,000.
• These amounts have been updated: as of the 2025 reviser’s update, the maximum per violation is now $27,874, and the cap for a related series is $139,356,994.
Implementation in 49 CFR Part 578 Current Dollar Values:
• For violations of the relevant Safety Act sections (including VIN requirements), the civil penalty is capped at $27,874 per violation, with a maximum of $139,356,994 for related series.
• If false or misleading reports are submitted, there’s a daily penalty of up to $6,823, with a series cap of $1,364,624.
Newmar and those that are publishing the false / misleading information regarding the vin can face the same stiff penalites.
