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: aiam2910OpenMr. Ralph T. Millet, Director, Governmental Relations, Saab-Scania of America, Inc., Saab Drive, P.O. Box 697, Orange, Connecticut 06477; Mr. Ralph T. Millet Director Governmental Relations Saab-Scania of America Inc. Saab Drive P.O. Box 697 Orange Connecticut 06477; Dear Mr. Millet: This is in response to your letter of 25 October 1978 concerning th requirements of S3.3 of Standard No. 201 as it applies to the instrument panel compartment door in the Saab 900. Your specific concern is the portion of S3.3 that provides, 'Additionally, any interior compartment door located in an instrument panel or seat back shall remain closed when the instrument panel or seat back is tested in accordance with S3.1 and S3.2.'; According to your letter, the hinges on the Saab 900 instrument pane compartment door are designed to deform to keep the compartment door closed if deformation resulting from the head impact requirements of S3.1 is great enough to open the compartment latch.; If the instrument panel compartment door remains closed during the hea impact tests of S3.1, the vehicle complies with that aspect of the requirements of S3.3 of Standard No. 201. The standard does not specify that the latch mechanism remain closed, only that the door 'shall remain closed.'; This interpretation should not be construed as an approval of Saab' instrument panel compartment door hinge system. Federal motor vehicle Safety standards are written primarily in terms of performance requirements which must be met in specified test, and a manufacturer is free to use any design it wishes to meet those performance requirements. Thus, this agency does not grant approval of specific systems or components in the vehicle. The manufacturer must exercise due care to assure that its vehicles comply with all applicable safety standards.; Please let me know if you have any further questions. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam4128OpenMr. Benjamin R. Jackson, Executive Director, Automobile Importers Compliance Association, 1607 New Hampshire Avenue, N.W., Washington, DC 20009; Mr. Benjamin R. Jackson Executive Director Automobile Importers Compliance Association 1607 New Hampshire Avenue N.W. Washington DC 20009; Dear Mr. Jackson: This responds to your letter following up our correspondence regardin the designation of the target zones under 49 CFR Part 541, *Federal Motor Vehicle Theft Prevention Standard*. In this letter, you quoted the statement in my February 4, 1986, letter to you that NHTSA 'knows of a number of means of inscribing numbers on curved surfaces that would permit direct importers to mark those surfaces within the $15 cost limit.' You asked me to provide information to you on the means of inscription to which I referred, including the name of the process and the address and the telephone number of supplier firms.; The means of inscribing curved surfaces to which I referred in m previous letter to you include technologies such as chemical etching, sandblasting, 'shot-peening', and hard-point vibration. Each of these technologies would enable a person to inscribe markings on curved surfaces, and none requires the purchase of very expensive equipment.; This agency does not provide commercial referrals of supplier firms fo a number of reasons. Section 606(c) of the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 2026(c)) requires each *manufacturer* to certify that its vehicles comply with the theft prevention standard. For this reason, NHTSA does not approve, endorse, or certify that any particular means of marking complies with the theft prevention standard. A listing of supplier firms might be viewed as an approval or endorsement of those firms and their means of marking, and be contrary to the statutory requirement.; Further, as a policy matter, this agency does not provide commercia referrals even absent statutory requirements. By listing a group of supplier firms, the agency would give those firms an unintended 'government sanction' for their products. Conversely, any such listing would unintentionally denigrate all firms not included in the listing. Any commercial referrals by this agency would give rise to these potential problems no matter what disclaimers NHTSA attached to the referral.; The theft prevention standard is a performance standard that specifie criteria with which the markings used by your group must comply. You are free to choose the means of compliance. In making that choice, you will have to use your business judgment to decide whether you should inscribe the markings yourself or pay someone else to inscribe the markings. If you choose to pay someone else to inscribe the markings, the choice of whom you should select would again be your decision.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3317OpenMr. Rick P. Golde, Project Engineer, Vetter Corporation, 1150 Laurel Lane, San Luis Obispo, CA 93401; Mr. Rick P. Golde Project Engineer Vetter Corporation 1150 Laurel Lane San Luis Obispo CA 93401; Dear Mr. Golde: This is in reply to your letter of May 28, 1980, with respect to you proposals for lighting requirements for a motorcycle sidecar currently under development. Your letter does not state so, but you indicated in your telephone conversation with Mr. Vinson of this office that the sidecar is detachable.; It has been the position of this agency that a detachable sidecar is a item of motor vehicle equipment to which no Federal motor vehicle safety standards apply. Conformance of the motorcycle therefore is judged without the sidecar attached. Therefore, the front turn signal configuration in Figure F2 would appear to meet Standard No. 108 but the asymmetrical one in Figures F1 and F3 would not. Similarly, the rear turn signal and stop lamp configurations in Figure R2 appear to comply, but those of Figures R1 and R3 do not. The configuration of Figure R4 is not prohibited by S4.1.2 since it does not appear to impair the effectiveness of the required lighting equipment. As for Figure R5, the reflective itself and its appearance solely on the sidecar, as indicated on your drawing, is improper. Finally, your Figure S1 depicts front and rear reflex reflectors mounted on the right side of the sidecar. This is not acceptable as a substitute for the required front and rear reflectors on the right side of the motor as you indicate but we believe it would enhance safety if you incorporated this idea into production.; If you have any further questions, please let us know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4578OpenPeter J. Yanowitch, Esq. Messrs. Davis, Markel, & Edwards 66 West Flagler Street, SUite 608 Miami, FL 33130 Re: Importation of Porsche 959; Peter J. Yanowitch Esq. Messrs. Davis Markel & Edwards 66 West Flagler Street SUite 608 Miami FL 33130 Re: Importation of Porsche 959; "Dear Mr. Yanowitch: This is in reply to your letter of February 27 l989, requesting a response by March l0 as to whether the Department would permit the importation of a Porsche 959 pursuant to l9 CFR 12.80(b)(1)(v). Specifically, you represent a non-resident of the United States who wishes to import such a vehicle, and operate it on the public roads of this country during the l-year period. You have asked for confirmation in writing that if the vehicle is imported on this basis that 'the Department of Transportation would not have jurisdiction to impound, confiscate, destroy, require a bond, or otherwise take any action with respect to the vehicle, so long as the non-resident fully complies with the provisions' of 12.80(b)(l)(v), and, further, that the Department 'would not object to the non-resident driving this vehicle on the road' while it is in the United States. You also state that your client is prepared to submit 'sworn testimony that he will comply with the requirements of the United States Customs Regulations.' Under l9 CFR 12.80(b)(l), each vehicle offered for introduction into the Customs territory of the United States shall be denied entry unless the importer files a declaration which declares that '(v) The importer...is a non-resident of the United States, is importing the vehicle...primarily for personal use for a period not exceeding l year from the date of entry, will not sell it in the United States during that period, and has stated his passport number and country of issue...in the declaration.' This provision was adopted in recognition of international treaties to which the United States is a party, which are intended to assure the free flow of international road traffic. However, this agency does not construe either the regulation or the treaties as conferring an absolute right upon any non-resident to import a non-conforming vehicle if considerations of policy dictate a determination that such entry would not be in the interests of the United States. Chief among these considerations is whether the importer has previously imported a motor vehicle in violation of the importation regulations. Accordingly, we wish to review your client's declaration before the time the vehicle arrives at the port of entry. I enclose a copy of our Form HS-7 for its completion and return to us. We request that a photocopy of the title or other certificate of ownership be enclosed as well. We also ask that a statement be attached to the declaration, so that it becomes a part of it and subject to penalties in the event that it is false or misleading, in which your client discloses whether he has ever imported into the United States any motor vehicle manufactured on or after January l, l968, and, if the answer is affirmative, to provide the make, model, and port and approximate date of entry, and the name of the importer or consignee as it appeared on the declaration. Finally, we also request an affirmation from your client that he will not sell the vehicle, or offer it for sale, either before or during its stay in the United States, and that he will export it at the end of the l-year period. When we have received and reviewed the declaration and statement we shall be pleased to consider this matter further, and we shall answer your questions at that time. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam1280OpenMr. Roy Case, Twin Coach Highway Products Incorporated, Kent, OH 44240; Mr. Roy Case Twin Coach Highway Products Incorporated Kent OH 44240; Dear Mr. Case: Thank you for your letter of August 22, 1973, concerning th requirements of Federal Motor Vehicle Safety Standard No. 217, Bus Window Retention and Release.; Following are answers to your four questions: >>>1. In a phone conversation with Richard Dyson on September 26 yo explained that the window mechanism in question (which you mentioned you are no longer using) requires the release of both mechanisms before the window releases -- that is, before the window will no longer conform to the retention requirements in paragraph S5.1, S5.1.1, and S5.1.2 of the standard. In this case, only one of the force applications necessary to operate both mechanisms need differ by 90 degrees to 180 degrees from the direction of the original push-out motion of the emergency exit.; 2. You are correct that the post in front of the window is not a obstruction so long as it permits passage of the ellipsoid. However, when a post cuts a window opening into two segments as shown in your enclosed sketch, only the segment that passes the ellipsoid, not the entire window opening, may count toward the measurement of total area specified in paragraph S5.2.; 3. Although Figure 3C shows only the boundaries for high and low forc access regions when the bus is upright (and when an obstacle is between the occupant and the unit), these same dimensions are these that are to be applied when the bus is overturned on either side, with the side on which the bus is resting being considered as the floor. The transposition of these dimensions is illustrated to some extent in Figure 3D.; Whether or not both rear windows must be made into emergency exit rests solely on whether both windows are necessary for the bus to meet the unobstructed opening requirements, and the emergency exit release requirements of S5.3 and S5.5 when the bus is upright and overturned on either side.; 4. The cut-off date for windows which do not comply with the standar is that of the date of manufacture of the bus in which the window is installed. All buses manufactured on or after September 1, 1973, must comply with the requirements of Standard No. 217.<<<; If I can be of further assistance, please do not hesitate to ask. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicle Programs |
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ID: aiam3747OpenMr. Al Desarro, Potemkin, 21111 South Dixie Highway, Miami, FL 33189; Mr. Al Desarro Potemkin 21111 South Dixie Highway Miami FL 33189; Dear Mr. Desarro: This is to follow up on your phone conversation with Stephen Oesch o my staff concerning the type of seat belts that must be used in a 1983 converted van that has a sofa.; Paragraph S4.2.2 of Safety Standard No. 208, *Occupant Cras Protection*, (copy enclosed) required trucks and multipurpose passenger vehicles with a gross vehicle weight rating of 10,000 pounds or less to meet the same requirements as passenger cars. This would include the vans in question. Paragraph S4.1.2.3 of the standard specifies that passenger cars must be equipped with a Type 2 seat belt assembly (non-detachable lap and shoulder belt) at each front outboard designated seating position. At all other seating positions, 2 seat belt assembly must be used. Thus, your vans must have Type 2 belts in the two front seats and either Type 2 or Type 1 belts in the rear seating positions, including the sofa. The agency's position regarding seat belts for sofa/beds used in van conversions is more fully explained in the enclosed interpretation letter of March 29, 1983, to Sherrod Vans, Inc.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4082OpenMr. Larry Alexander, Senior Product Manager, Consumer Products Division, Tuck Industries, Inc., Lefevre Lane, New Rochelle, NY 10801; Mr. Larry Alexander Senior Product Manager Consumer Products Division Tuck Industries Inc. Lefevre Lane New Rochelle NY 10801; Dear Mr. Alexander: This is in reply to your letter of October 1, 1985, asking whether an of your pressure sensitive tapes packaged for the automotive aftermarket are subject to any regulations of the National Highway Traffic Safety Administration. You have been asked by one of your customers to certify that your tape meets all applicable Federal motor vehicle safety standards and other regulations.; You provide four types of tapes: lens repair tape (for temporary us until a broken lens is replaced), hose repair tape (for temporary repair of leaks in water hoses), clear patch tape (for repair of upholstery), and carpet tape (used to hold carpets in place). This agency has jurisdiction over items of motor vehicle equipment, which are defined in part as:; >>>any system, part or component of a motor vehicle as originall manufactured or any similar part or component manufactured or sold for replacement or improvement of such system, part, or component or as any accessory or addition to a motor vehicle....'<<<; Your tape could be regarded as an 'addition' to a motor vehicle bu even assuming that it is an item of motor vehicle equipment, there are no Federal motor vehicle safety standards that would apply to it. Therefore, no manufacturer certification is required, and you may so inform your customer. Further, any such certification could be viewed as a violation of the National Traffic and Motor Vehicle Safety Act by being certification that is false and misleading in a material respect, stating compliance with standards which are, in fact, non-existent.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0868OpenMr. Charles E. Packard, Senior Engineer, Clay Equipment Corporation, Cedar Falls, IA 50613; Mr. Charles E. Packard Senior Engineer Clay Equipment Corporation Cedar Falls IA 50613; Dear Mr. Packard: This is in reply to your letter of September 5, 1972, in which yo enclose a copy of your brochure describing a 'Honey Wagon' and ask what our requirements are.; The 'Honey Wagon' described in your brochure appears to be manufacture primarily for off-road use. The National Traffic and Motor Vehicle Safety Act and the Federal Motor Vehicle Safety Standards do not apply to off-road use vehicles.; If you have further questions, I will be pleased to answer them. Sincerely, Francis Armstrong, |
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ID: aiam2855OpenMr. Bruce Henderson, Vice-President, Motorcycle Trades Association, Inc., 510 N. Washington, P.O. Box 132, Alexandria, VA 22313; Mr. Bruce Henderson Vice-President Motorcycle Trades Association Inc. 510 N. Washington P.O. Box 132 Alexandria VA 22313; Dear Mr. Henderson: This responds to your letter concerning the edge treatment requirements of Safety Standard No. 205, *Glazing Materials*, as they would apply to rigid or flexible plastics to be used for windshields on motorcycles. You asked for confirmation that one-piece plastics are required to meet the edge treatment requirements set forth in the standard for non- laminated glass.; The edge treatment requirements of Standard No. 205 are specified i paragraph S5.2, which incorporates by reference the SAE Recommended Practice J673a, Automotive Glazing,' August 1967. The SAE Practice specifies different requirements for tempered' and laminated' safety glass. The agency interprets the distinctions to apply equally to plastics. Therefore, one-piece plastic materials must meet the edge treatment requirements specified for tempered' glazing, and laminated plastics must meet the requirements specified for laminated' glazing.; Please contact this office if you have any further questions. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2506OpenMr. Karl-Heinz Ziwica, Manager, Safety Engineering, BMW of North America, Inc., Montvale, New Jersey 07645; Mr. Karl-Heinz Ziwica Manager Safety Engineering BMW of North America Inc. Montvale New Jersey 07645; Dear Mr. Ziwica: This is in response to your January 17, 1977, letter concerning th requirements of Safety Standard No. 111, *Rearview Mirrors*, For passenger cars. You requested confirmation of your interpretation that the standard specifies no requirements for outside rearview mirrors on the passenger's side of the vehicle when the inside rearview mirror meets S5.1.1 of the standard.; Your interpretation is correct. If the inside rearview mirror of passenger car meets the specified performance requirements, the vehicle is not required to be equipped with an outside rearview mirror on the passenger's side. However, a manufacturer is free to equip its vehicles with outside right-hand mirrors, either plane or convex, if he choses(sic).; You should note that each passenger car whose inside rearview mirro does not meet the field of view performance requirements of Paragraph S5.1.1 must have an outside rearview mirror of unit magnification installed on the passenger's side of the vehicle.; Sincerely, Frank Berndt, Acting 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.