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An Exploration into Vans, VINs, Headrests, and Highway Safety

Updated: Oct 14, 2023

Admit've wondered when Canoo is going to get their 5-star crash test rating. Well, as you may know, pretty much every vehicle in the world has a VIN number. And as you also may know, the Canoo Lifestyle Vehicle’s rear side-facing seats do not have headrests. If that answer has you confused, read on to find out the engineering concept that connects these three seemingly random things!


How a van gets a VIN

If you’ve ever registered an automobile (or moped, motorcycle, scooter, or any kind of towed vehicle), you’ve had to provide a Vehicle Identification Number (VIN). On a car or truck, it’s usually nested underneath the windshield, in the dashboard in front of the steering wheel. VINs are unique, and each digit of this number serves as a universally standardized way to identify specific characteristics of the vehicle in question, as seen in the image below:

VIN digit-by-digit breakdown

While a vehicle manufacturer is ultimately the entity that assigns a VIN, they only have control over digits four through seventeen. The first three digits are what is known as a World Manufacturing Identifier (WMI), and these digits are governed worldwide by an organization known as SAE International.

The first digit of the WMI signifies a world region, the second signifies a country, and the third signifies a specific manufacturer. A country's national affiliated organization assigns WMIs to manufacturers located within that nation's borders. In the United States, SAE is responsible for assignment.

Okay, yeah, but what’s that got to do with Canoo?

Canoo was assigned a WMI code earlier this year: 7TN.

If that strikes you as a little odd, you’re on to something. For a long time, car manufacturers in the USA have only had WMIs that begin with 1, 4, or 5. However, in 2009, the first-digit value of 7, which had previously been reserved for the Oceania region (Australia/New Zealand), was made available to other countries, and some time after that, it was granted to the USA by SAE. (So many acronyms!)

Notably, Tesla, Rivian, Zoox, Xos, Lordstown, Faraday Future, and (gulp!) Electric Last Mile Solutions have all been assigned WMIs with a first digit of 7 — it seems that, among other uses, this newly available set of WMIs will likely be used for the influx of new electric car manufacturers over the coming years.

Why is there a WMI at all?

Wherever you find engineers, you will find industry standards. Engineers are constantly working to invent and improve processes and products, and when breakthroughs are made, proposals are made to add these advancements to standards across their field.

Standards are more than guidelines; they’re specific, intentional, codified rules. Standards are pivotal to our daily lives, and most of us take them for granted. They are why, for example, when you plug in an HDMI cable from your computer to your monitor, no matter who manufactured it, it just works. Whichever cord manufacturer created your specific HDMI cable made sure that each dimension of it, from the pin size to the plug depth to the materials used, followed a recommended specification or specified range. Likewise, the people who designed the ports on your computer and monitor had to follow exact specs to make sure that when you plug in any HDMI cable between them, it fits and functions properly. Standards ensure compatibility between systems, databases, physical products, and legal frameworks.

With auto manufacturers building and selling cars in all corners of the world, it only makes sense that a standardized system would be created to account for registering them. Most, if not all countries, abide by the SAE standard for WMI assignment.

However, we should point out something about standards. Engineering is, fundamentally, the application of science and math to solve problems. A universally agreed-upon best option, though, is not always reached. Instead, there are usually best efforts to solve problems, each with inherent benefits and drawbacks. And then there’s the matter of taste in design, which is subjective and not really related to mathematical or scientific truths. Because of all these factors, you often get many different parties suggesting or endorsing their idea of a best option.

XKCD "competing standards" comic

That’s how you get something like international power plugs, where different countries have adopted different options (it’s so complicated that there are tools to help you figure it out).

See, a standard is not a universal truth, but rather the accepted "best option", and it’s fully opt-in, so the “best option” may be different between countries, or even between companies.

For instance, the U.S. and Europe have a different set of accepted standards for highway safety in vehicle manufacturing. In the U.S., the set of standards is known as the Federal Motor Vehicle Safety Standards (FMVSS), and is governed and enforced by the National Highway Traffic Safety Administration (NHTSA). In Europe and other parts of the world, the United Nations Economic Commission for Europe (ECE or UNECE) oversees vehicle regulations. These two sets of regulations are similar, but different enough that they are incompatible.

Okay, okay, but how does that relate to Canoo?

Canoo’s utilization of space allows for the “loft on wheels” experience that they tout in the Lifestyle Vehicle, including retractable seats built into the rear passenger doors. However, like many of you, as soon as we saw these seats, we wondered about the legality of seats with no headrests behind them. The answer has to do with the disparity between the FMVSS and ECE standards for safety.

Pictured: the LV side seat with no visible headrest. Credit: me, cormboi!

Since many different vehicles are made in Europe and then sold to the U.S., problems arise when a manufacturer’s adherence to ECE standards does not translate over to U.S. standards.

One of these instances regards headrests. In 2004, to solve some of this existing disparity, NHTSA made an effort to marry the headrest regulations of the ECE with those of the FMVSS. In that rule, NHTSA said explicitly that “this final rule does not mandate rear outboard head restraints. However, this rule does require that the voluntarily installed rear outboard head restraints meet the energy absorption requirements discussed above.”

In the three NHTSA rules on the subject since then, rear head restraints have been referred to as “optional”, “voluntarily provided”, or “voluntarily installed”.

In plain English: our amateur interpretation is that while the Canoo’s rear side-facing seats have to have a seat belt, it seems they are not required to have headrests*. One imagines that Canoo will incorporate some kind of pillar airbags to protect these side passengers’ heads in the event of a crash, but that remains to be seen.

Speaking of crashes…

Anybody shopping for a car is looking for a 5-star crash test rating to protect themselves and their family the best that they can. Few people, though, know that a "crash test rating" from 1-5 stars is not actually required — around half a million cars are sold each year that do not have crash test ratings from either NHTSA or IIHS (an independent research firm), according to Consumer Reports. From the NHTSA website: "The National Highway Traffic Safety Administration’s New Car Assessment Program (NCAP) created the 5-Star Safety Ratings Program to provide consumers with information about the crash protection and rollover safety of new vehicles beyond what is required by Federal law."

In fact, numerous electric and even long-standing ICE vehicles on the road today do not have crash test ratings from either organization, so the fact that Canoo is not yet certified is not cause for concern — we shouldn’t be counting the moments until they come out with a rating, because it may not happen for a few years.

When choosing vehicles to test for crash test rating, these two organizations try to cover the most popularly available vehicles in order to maximize their budgets to cover the biggest swath of cars on the road. Both NHTSA and IIHS anonymously purchase freely available vehicles from dealers so that manufacturers cannot fudge the results. Thus, it may be a while until Canoo sees a vehicle receive a rating from either of these agencies.

So wait…how do I know that cars on the road are safe?

Aha! It all comes back to those pesky standards. Because the rules and regulations for vehicle specifications are made so specifically clear and measurable in the FMVSS, manufacturers must test their own cars and create them to the specs laid out in those FMVSS standards, which lay out everything from the tensile strength of an activated seat belt, the impact force that a seat must be able to withstand in a crash — even the specific dimensions of a crash test dummy — and much, much more, including the aforementioned VIN.

So when you see those videos of Canoo's self-performed crash testing, that’s not some extra thing that Canoo is electing to do — though they may be a bit more thorough than other companies swimming in this great big EV ocean — that’s just Canoo’s marketing doing a great job filming the tests they were required to execute on their own cars before bringing them to market.

Actually, that's Canoo's marketing doing an incredible job. Credit: Canoo

When submitting to NHTSA, manufacturers must provide diagnostics from these tests that prove their vehicle is up to snuff on the myriad requirements laid out by the FMVSS. So, when the LV finally makes it to market in 2023, it’ll be safe to say it’s safe.

Like this article? Follow me on Twitter @cormboi for more insights and opinions on Canoo and the EV industry!


*Update 11/13/2022: Re: the side-facing seats — our amateur interpretation of the NHTSA rule is predicated on the idea that the side-facing seats would be considered "designated seating positions". Because they retract into the doors, there could be an argument made that these seats qualify as "jump seats" or "auxiliary seats", as detailed in this interpretation from NHTSA, which would exclude them from multiple requirements in Standards 207, 208, and 210. A rule was proposed in 2005 that would have removed some exclusions for jump seats, but as far as we can tell, no formal rule was ever made in that respect.

*Update 12/7/2022: Justin Banner at MotorTrend elaborated on Canoo's crash testing and crashworthiness outlook in a article, with some comments taken from a video featuring Canoo's Global VP of Commercial/Fleet Sales, Gary Gumushian.

Authors disclosures: I am long Canoo - I own common shares.


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