Key points
- Articles 41 and 42 govern EU and national small-series type-approval routes.
- The WMI third-character 9 rule comes from Annex II to EU 2021/535.
- Global production below 500 vehicles does not by itself define the approval route.
- Confirm approval limits and WMI/VIS assignments separately.
Small-series approval is an approval route
Articles 41 and 42 of Regulation (EU) 2018/858 provide EU and national routes for vehicles produced in small series, subject to the applicable annual quantitative limits and technical conditions. National small-series approval has territorial and recognition rules described in Article 43.
These provisions concern how a vehicle type is approved and placed on the market.
The third WMI character is a manufacturer-identification rule
Annex II to Implementing Regulation (EU) 2021/535 says the third WMI character is 9 when the manufacturer’s global production is below 500 vehicles per year. The competent authority then assigns the third, fourth and fifth VIS characters to complete the manufacturer identification.
This rule concerns VIN composition, not the selection of an approval route.
Plan the two decisions separately
First confirm the applicable approval route and quantitative limit with the competent authority. Separately confirm the assigned WMI and any authority-assigned VIS characters.
A VIN profile should reproduce those assignments exactly and leave approval-route information in dedicated reference fields.
ManageVIN is a calculation and record-management aid. It does not assign WMI codes and does not replace an approval authority or professional compliance review.
