NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: aiam4532OpenJerry Swisher, Esq. Cooper Tire & Rubber Co. Findlay, OH 45840; Jerry Swisher Esq. Cooper Tire & Rubber Co. Findlay OH 45840; "Dear Mr. Swisher: This responds to your letter of May 20, 1988, i which you sought an interpretation of Standard No. 109, New Pneumatic Tires - Passenger Cars (49 CFR 571.109). Specifically, you asked if either of three proposed courses of action would comply with the labeling requirements specified in S4.3.2 of Standard No. 109. That section reads as follows: 'Each tire shall be labeled with the name of the manufacturer, or the brand name and number assigned to the manufacturer in the manner specified in Part 574.' None of your proposed courses of action would satisfy this requirement, as explained below. You first asked if it is permissible to have no identification on the sidewall as to the name of the manufacturer or the brand name owner, but to simply use the identification numbers assigned to Cooper Tire under Part 574. Section S4.3.2 of Standard No. 109 explicitly requires each tire to be labeled with the manufacturer's name or a brand name and the identification number assigned to the manufacturer. Tires that are identified solely by an identification number would not comply with this requirement. Second, you asked if a tire could be labeled with three different brand names. Section S4.3.2 uses the singular tense to identify the name that must appear on the sidewall (name of the manufacturer or the brand name) and connects the alternative with the disjunctive 'or.' This grammatical structure indicates that only one name, either that of the actual manufacturer or the brand name owner, shall be labeled on the tire. The agency chose this grammatical structure to ensure that consumers would not be confused about the identity of the brand name or manufacturer of the tire. Accordingly, S4.3.2 prohibits Cooper from selling passenger car tires labeled with the names of three different brand name owners. Third, you asked if a generic term such as 'All Season' or 'Performance' would satisfy the requirement of S4.3.2 that either the name of the manufacturer or a brand name be labeled on the tires. Clearly, a generic term like 'Performance' is not the 'name of the manufacturer,' Cooper in this case. The 'brand name' refers to the name under which a tire is sold at retail, whether it is identical to the manufacturer's name (e.g., Firestone), a name owned by the manufacturer and used in place of its corporate name (i.e., a house brand, such as Falls that is manufactured by Cooper), or a name owned by someone other than the manufacturer (i.e., a private brand such as Atlas that is made by several manufacturers). My understanding of this proposed course of action is that the tires would be advertised and sold at retail as tires made by one of the three brand name owners, presumably using its brand name, not under the name 'All Season' or 'Performance.' Therefore, these generic terms would not be considered brand names for the purposes of section S4.3.2. If you have any further questions or need additional information on this subject, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam0822OpenMr. Thomas C. Morrill, Vice President, State Farm Mutual Automobile Insurance Company, Bloomington, IL 61701; Mr. Thomas C. Morrill Vice President State Farm Mutual Automobile Insurance Company Bloomington IL 61701; Dear Mr. Morrill: This is in further response to your letters of May 3 and August 8 1972, requesting that the NHTSA make available to insurance companies, such as State Farm, 'vehicle identification numbers' (VIN's) which the companies could then utilize to independently notify policyholders whose vehicles have been subject to manufacturers' defect notification campaigns.; The NHTSA has reconsidered your request and has determined to propose as an amendment to our Defect Reports regulations (49 CFR Part 573), that manufacturers be required to submit to the NHTSA the VIN's of vehicles subject to campaigns. The VIN's would be included in our public file and would be available to insurance companies and other groups who would wish to use them.; The NHTSA does not presently require manufacturers to submit the VIN' of campaigned vehicles (although the Defect Reports regulations do require manufacturers to compile the numbers for their own use). Because this will be a new requirement, the NHTSA is obligated by law to initiate rulemaking to provide for comments by interested persons, and to consider such comments in the decision as to whether the rule should be issued. We will take steps to publish the appropriate notice in the nearest possible future.; Your continuing interest in motor vehicle safety is, of course, greatl appreciated.; Sincerely, Douglas W. Toms, Administrator |
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ID: aiam1730OpenMs. Brenda Nolan, P.O. Box 172, Action, MA 01720; Ms. Brenda Nolan P.O. Box 172 Action MA 01720; Dear Ms. Nolan: A copy of your October 21, 1975, letter to Peterson Baby Products ha been forwarded to this agency by the Consumer Product Safety Commission for our consideration. In your letter, you indicated to the Peterson Company that you have experienced problems with their 'safety shell' child carrier as follows: A child can climb out of one model, vehicle seat belts do not readily attach to one model, while in both models, directions for adjustment of a tether strap appear inadequate, the child harness system does not adjust easily, and the padding materials are insufficiently durable.; Safety Standard No. 213, *Child Seating Systems*, regulates certai safety aspects of the type of child restraint system that seats a child for transportation in a motor vehicle. Peterson products subject to the requirements of the standard have been tested under NHTSA enforcement programs without failure.; Standard No. 213 does not include durability requirements for th padding or other material of the device. The standard does establish requirements for the retention of a simulated child's torso in the system when it is subject to frontal crash forces. This test, however, would not ensure that a child would be retained in the system if it attempted to release itself from the system. A 'child proof' system would make routine release by the parent extremely difficult.; As for belt webbing, the present standard only requires tha installation instructions be provided with the system, and that the webbing fit snugly those children for which the system is recommended. There are no requirements for the ease of seat belt hardware operation.; The NHTSA has proposed a more comprehensive child restraint standar that would regulate all child restraint systems, and would subject them to testing under dynamic loads that should result in upgraded performance of child restraint systems. I have forwarded your letter to the public docket on this rulemaking so that your views will be considered in the rulemaking process.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0988OpenSenator Herman E. Talmadge, Senate Office Building, Washington, DC 20510; Senator Herman E. Talmadge Senate Office Building Washington DC 20510; Dear Senator Talmadge: This is in reply to your inquiry of January 16, 1973, on behalf of you constituent, Mr. Ski Bashinski. As Executive Director of the Georgia Independent Auto Dealers Association, Mr. Bashinski was concerned that the Federal Odometer Disclosure Requirements might become effective at a date earlier than that suggested in the notice of proposed rulemaking on the subject.; The regulations to which Mr. Bashinski refers were proposed by th National Highway Traffic Safety Administration on December 2, 1973, (sic) pursuant to Title IV, Odometer Requirements, of the Motor Vehicle Information and Cost Savings Act, P.L. 92-513. The effective date proposed was six months after issuance of a rule.; After reviewing the comments to its proposal, the NHTSA issued th Odometer Disclosure Requirements as a final rule on January 31, 1973. In the light of comments indicating a need for a prompt effectiveness, the rule will go into effect March 1, 1973. The other provisions of Title IV went into effect by operation of law on January 18, 1973, and require the assistance of the disclosure statement if they are to be fully effective.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4162OpenThe Honorable Edward F. Reilly, Jr., Kansas Senate, 430 Delaware Street, Leavenworth, KS 66048; The Honorable Edward F. Reilly Jr. Kansas Senate 430 Delaware Street Leavenworth KS 66048; Dear Mr. Reilly: Thank you for your letter enclosing correspondence from Mr. Dennis D Furr of Lansing, Michigan.; As we understand his letter, Mr. Furr contacted you to express hi concern about a Michigan state law which permits loading school buses up to 110 percent of the number of persons for which the bus has a rated seating capacity. He believes that installation of safety belts in school buses would reduce the likelihood that excessive numbers of children would be carried on each school bus seat.; You asked for information on Mr. Furr's suggestion for school bu safety belts. I am pleased to explain the two sets of regulations we have for school buses, both of which are relevant to school bus seating accommodations. Before I begin, I would like to note that in July 1985, we responded to an inquiry on Mr. Furr's behalf from U.S. Senator Donald W. Riegle, Jr., asking about requirements limiting school bus passenger capacities. In our response, we explained how manufacturers currently determine the passenger capacities of their school buses and that we know of no safety problem related to their calculations. A copy of our letter is enclosed for your information.; As explained in our letter to Senator Riegle, the first set o regulations we have for school buses, issued under the authority of the National Traffic and Motor Vehicle Safety Act, includes our motor vehicle safety standards which apply to the manufacture and sale of new school buses. Some of Mr. Furr's concerns involve one of those safety standards, Standard No. 222, *School Bus Passenger Seating and Crash Protection*, which specifies requirements for safety belts in small school buses. Standard No. 222 currently does not require safety belts for passengers in large school buses (those with gross vehicle weight ratings greater than 10,000 pounds) because large school buses are already required to provide high levels of protection to passengers through a concept called 'compartmentalization.' Compartmentalization requires that the interior of large buses be improved so that children are protected without the need to fasten safety belts. The seating improvements include higher and stronger seat backs, additional seat padding, and better seat spacing and performance. Our safety standards do require safety belts for passengers in smaller school buses since those buses do not offer the same protection as that provided by compartmentalization.; In his letter to you, Mr. Furr appears to be primarily concerned wit overloaded school buses and believes that safety belts would prevent schools from overcrowding school bus bench seats. We believe that this rationale for safety belts does not warrant a Federal requirement for belts on large school buses, since large school buses offer substantial protection to passengers and safety belts per se will not prevent users from overcrowding their buses. Thus, requiring safety belts in large school buses under Federal law would not assuredly lessen overcrowding of buses, and any possible improvement in seating accommodations would not be achieved.; On the other hand, we do not prevent States and local school district from ordering safety belts on their large school buses if they wish to do so. Thus, States may order school buses with safety belts if they believe this would reduce the likelihood that school buses would be overloaded. Issues relating to safety belts in large school buses are discussed in NHTSA's publication entitled, 'Safety Belts on School buses,' June 1985. I have enclosed a copy of the report for your information.; Our second set of regulations for school buses, issued under th highway Safety Act, consists of recommendations to the States for operating their school buses and applies to Federal funding of State highway safety programs. Those recommendations are found in Highway Safety Program Standard No. 17, *Pupil Transportation Safety* (copy enclosed, which Mr. Furr refers to as 'Federal Standard 17.' This 'standard,' or guideline, recommends that States provide seating accommodations of minimum specified dimensions for each school bus occupant and that States coordinate seating plans to eliminate standees. To reiterate, however, Program Standard No. 17 is a guideline for the States and its adoption is determined by the States. We have no reason to believe that Michigan has not evaluated thoroughly its pupil transportation needs in determining whether to implement the standard's recommendations.; I hope this information is helpful. Please let me know if we can be o further assistance.; Sincerely, Diane K. Steed |
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ID: aiam1360OpenMr. George H. Jones, Manager, Louisiana Independent Tire Dealers Association, 4500 5th Avenue So. No. 307, Birmingham, AL 35212; Mr. George H. Jones Manager Louisiana Independent Tire Dealers Association 4500 5th Avenue So. No. 307 Birmingham AL 35212; Dear Mr. Jones: This is in reply to your letter of November 14, 1973, to Michael Pesko of our Chief Counsel's Office, asking whether dealers must record the name and address of the tire purchaser on the appropriate form at the same time the tire is sold. You indicate that most dealers record the information on their sales tickets and put it on registration forms at some later time, as the press of business allows.; The Tire Identification and Recordkeeping regulations (49 CFR Part 574 do not require dealers to record the information on the registration form at any specific time. The 'scare stories' to which you refer are not true at all. A recent NHTSA investigation of dealer recording practices was intended only to discover whether dealers were writing down the tire ID number and the purchaser's name, and not whether they were recording the information on particular forms.; The Tire Identification regulation (S 574.8(b)) requires th information to be supplied to the manufacturer (or person maintaining the information) every 30 days, unless less than 40 tires are sold (your letter to us incorrectly stated less than 60 tires), in which case the information must be reported when 40 tires are sold or 6 months elapses, whichever occurs first.; I hope this clarifies the situation. Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4498OpenMrs. Patricia Bicking 1132 Chestnut Avenue Woodbury Heights, NJ 08097; Mrs. Patricia Bicking 1132 Chestnut Avenue Woodbury Heights NJ 08097; "Dear Mrs. Bicking: This is a response to your letter of last fall i which you asked a number of questions concerning seat-belts and large school buses. I apologize for the delay in responding. In your correspondence, you enclosed a letter of January 19, 1984, from this Office to Thomas Built Buses, Inc., (Thomas), and the incoming letter from Thomas that was the basis of our interpretation. Your first question references the January 1984 letter, and asks why the National Highway Traffic Safety Administration (NHTSA) decided that when school bus manufacturers install seat-belts or seat-belt anchorages on large school buses (over 10,000 lbs. gross vehicle weight rating GVWR ), the manufacturers do not have to certify that the belts or anchorages meet Federal motor vehicle safety standards 208, 209, and 210. The answer to this question is that NHTSA does not require a school bus manufacturer to install seat-belts on large school buses. Our regulations require a motor vehicle manufacturer to certify compliance to all applicable standards. You ask whether this decision still stands. The answer to that question is 'yes' for the reason just stated. The agency does not require large buses to have seat-belts because the 'compartmentalization' concept (to which you allude in your letter) supplies adequate protection for passengers in large school buses. Let me give you some background information on our school bus regulations that I think will help address your questions. The National Highway Traffic Safety Administration (NHTSA) is responsible for developing safety standards applicable to all new motor vehicles, including school buses. In 1977, we issued a set of motor vehicle safety standards regulating various aspects of school bus performance. Among those standards is Standard 222, School Bus Passenger Seating and Crash Protection. Standard 222 requires large school buses to have passenger crash protection through 'compartmentalization.' Compartmentalization requires large school buses to incorporate certain protective elements into the vehicles' interior construction, thereby reducing the risk of injury to school bus passengers without the need for safety belts. These elements include high seats with heavily padded backs and improved seat spacing and performance. (Our regulations require a safety belt for the school bus driver because the driver's position is not compartmentalized. Further, because small school buses experience greater force levels in a crash, passengers on these vehicles need the added safety benefits of the belts.) You also asked whether there have been any improvements in school bus seating compartments since 1977, and whether the improvements are mandatory. The answer to your question is that there have been no major changes in the school bus safety standards since they became effective in April, 1977. However, the agency continuously reviews school bus safety standards to assess whether it is appropriate to add or amend a requirement. You may be interested to know that school buses continue to have one of the lowest fatality rates for any class of motor vehicle. Large school buses are among the safest motor vehicles because of their size and weight (which generally reduce an occupant's exposure to injury-threatening crash forces), the drivers' training and experience, and the extra care other motorists take when they are near a school bus. For these reasons, NHTSA has not required safety belts in large school buses. I hope you find this information helpful. If you have further questions, please contace Joan Tilghman, of my staff, at (202) 366-2992. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam5323OpenMr. Scott Slaughter Pitts Enterprises, Inc. 5734 Highway 431 P.O. Box 155 Pittsview, AL 36871; Mr. Scott Slaughter Pitts Enterprises Inc. 5734 Highway 431 P.O. Box 155 Pittsview AL 36871; "Dear Mr. Slaughter: This responds to your inquiry about whether logging trailer known as the 'knuckle boom loader trailer' that you manufacture is a motor vehicle that would have to comply with the applicable Federal Motor Vehicle Safety Standards. You explained that your trailer stays in the woods the majority of its life and is infrequently transported over public roads between job sites. I am pleased to have this opportunity to explain our regulations to you. This agency interprets and enforces the National Traffic and Motor Vehicle Safety Act ('Safety Act' 13 U.S.C. 1392 et seq.) under which the Federal Motor Vehicle Safety Standards are promulgated. The Act defines the term 'motor vehicle' as follows: 'any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails.' Whether the agency considers your trailer to be a motor vehicle depends on its use. It is the agency's position that this statutory definition does not encompass mobile construction equipment, such as cranes and scrapers, which use the highway only to move between job sites and which typically spend extended periods of time at a single job site. In such cases, the on-highway use of the vehicle is merely incidental and is not the primary purpose for which the vehicle was manufactured. In contrast are instances where vehicles, such as dump trucks, frequently use the highway going to and from job sites, and stay at a job site for only a limited time. Such vehicles are considered motor vehicles for purposes of the Safety Act, since the on-highway use is more than 'incidental.' Based on the available information, it appears that your trailer is not a 'motor vehicle' within the meaning of the Safety Act. This conclusion is based on statements in your letter and brochures that this equipment spends extended periods of time at a single construction site and only uses the public roads infrequently to move between job sites. Thus, the agency would consider the use of your device on the public roads to be incidental and not its primary purpose. Since your trailer is not a motor vehicle, it would not be subject to our Federal Motor Vehicle Safety Standards. If the agency were to receive additional information indicating that your trailer used the roads more than on an incidental basis, then the agency would reassess this interpretation. If the agency were to determine that your trailer is a motor vehicle, then the trailer would have to comply with the applicable Standards, including Standard No. 108 Lamps, Reflective Devices, and Associated Equipment, which addresses conspicuity, Standard No. 115, Vehicle Identification Numbers, Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars, and Standard No. 121 Air Brake Systems which requires automatic slack adjusters and brakes to act on all wheels. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0121OpenMr. R. Hoffman, Service Department, Rockford Motors, Incorporated, 1911 Harrison Avenue, Rockford, Illinois 61101; Mr. R. Hoffman Service Department Rockford Motors Incorporated 1911 Harrison Avenue Rockford Illinois 61101; Dear Mr. Hoffman: Thank you for your letter of July 30, 1968, in which you reques additional information in regard to certification requirements.; The statement in your letter to the effect that because detailed labe requirements are now being prepared, you are not required to affix a certification label on your motorcycles currently being manufactured is not exactly correct. The 'Certification Requirement Notice,' published in the Federal Register, Volume 32, Number 215, dated November 4, 1967, a copy of which is enclosed, states that a certification label or tag should be affixed to each applicable motor vehicle if manufactured on or after January 1, 1968. In your case the only safety standard that currently involves motorcycles is Number 205, 'Glazing Materials,' pertaining to windshields. On January 1, 1969, another safety standard, Number 108, 'Lamps, reflecting Devices, and Associated Equipment,' will involve motorcycles manufactured on or after that date.; For your immediate information, a copy of the Federal Motor Vehicl Safety Standards with Amendments is enclosed, with particular attention called to Table III, page MVSS 108-18 (1969) and Table IV, page MVSS 108-20 and 21 (1969).; In regard to your question as to whether you have to add the year o manufacture to your serial numbers, this is not a specific requirement, but would be an aid to clarifying the serial numbering system that identifies applicable vehicles as manufactured on or after January 1, 1968.; The study involving the possibility of specific changes t certification requirements is currently in the proposed rule making category and if changes do become finalized they will be published in the Federal Register.; Please furnish this office with the requirements shown in paragraph in the enclosed Certification Requirement Notice at your earliest convenience.; I trust this information will be of assistance to you in regard to you inquiries.; Sincerely, Francis Armstrong, Director, Office of Performance Analysis Motor Vehicle Safety Performance Service; |
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ID: aiam4861OpenMr. H. Hurley Haywood Vice President Brumos Motor Cars, Inc. 10231 Atlantic Boulevard Jacksonville, FL 32225; Mr. H. Hurley Haywood Vice President Brumos Motor Cars Inc. 10231 Atlantic Boulevard Jacksonville FL 32225; "Dear Mr. Haywood: This responds to your letter of March 20, 1991 wit respect to 'the sale of a very limited number of specially built cars in the U.S.' Components would be manufactured by Porsche. The chassis would be 'a carbon fiber 962 racing tub' with a hand built body. The car could be imported either as an assembled vehicle or as a kit and assembled here. You have asked for information regarding 'low volume manufacturers exemptions from certain DOT regulations, emissions, passive restraints, bumper height, and all other pertinent information regarding manufacturing and sale of vehicles in the U.S.' You have not enclosed a photo of the car but your remark that the chassis is a 'racing tub' raises the possibility that the vehicle may be intended for racing purposes. Single-seat vehicles imported for competition on closed circuit courses and not used on the public roads are generally not 'motor vehicles' under the National Traffic and Motor Vehicle Safety Act, and no regulations apply to them. If you wish to pursue this possibility further, please send us more information on the vehicle. Assuming that the car is subject to the Safety Act, its manufacturer is eligible to apply for a temporary exemption from one or more of the Federal motor vehicle safety standards on several grounds. Exemptions of up to three years may be provided a manufacturer whose total motor vehicle production was 10,000 units or less in the year preceding the filing of its petition. Alternatively, exemptions of up to two years may be provided covering up to 2,500 vehicles per year if the manufacturer-petitioner can demonstrate that the exemption would facilitate the field evaluation of innovative safety features or low-emission vehicles, or if, in the absence of an exemption, the manufacturer would be prevented from selling a motor vehicle whose overall level of safety is at least equivalent to that of a vehicle complying with all the safety standards. However, the exemption authority extends only to the safety standards. The bumper height standard was issued under the authority of the Motor Vehicle Information and Cost Savings Act which contains no exemption provisions. The emission standards are issued by the Environmental Protection Agency, which is not part of the Department of Transportation, and you will have to contact them as to their requirements. If the intent is to import a fully assembled motor vehicle into the United States, at the time of entry it will have to bear the certification of its manufacturer that it complies with all applicable Federal motor vehicle safety, bumper, and theft prevention standards (the certification label must also list the standards from which exemptions may have been provided). If the intent is to ship the vehicle in a disassembled state for assembly by the purchaser or manufacturer's agent in the United States, and if the kit contains l00% of the parts necessary for assembly, we regard the foreign supplier as the 'manufacturer', responsible for ensuring compliance with all Federal requirements, including provision of certification. I enclose an information sheet with respect to the regulations that we administer, and will be pleased to answer any further questions you may have. If you prefer to telephone, Taylor Vinson of this Office will be able to help you (202-366-5263). Sincerely, Paul Jackson Rice Chief Counsel"; |
Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.