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: aiam2613OpenMr. Matt Kolb, Suite 937 Spitzer Building, Toledo, OH 43604; Mr. Matt Kolb Suite 937 Spitzer Building Toledo OH 43604; Dear Mr. Kolb: This responds to your April 18, 1977, letter asking whether ou regulations pertaining to truck-camper loading apply to trucks designed to haul fifth-wheel trailers.; Truck manufacturers are required to supply information pertaining t the cargo weight rating and longitudinal limits for the center of gravity of those vehicles capable of accommodating slide-in campers (Code of Federal Regulations, Volume 49, Part 575.103, *Truck-camper loading*). Slide-in camper is defined as 'a camper having a roof, floor, and sides, designed to be mounted on and removable from the cargo area of a truck by the user.' The purpose of this information requirement is to lessen the possibility of vehicle overloading. Since fifth-wheel trailers do not fall within the definition of slide-in camper, the regulations pertaining to truck-camper loading do not apply to vehicles designed to haul these trailers.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3901OpenMr. T. Chikada, Manager, Automotive Lighting, Engineering Control Dept., Stanley Electric Co., Ltd., 2-9-13, Nakameguro, Meguro-ku, Tokyo 153, Japan; Mr. T. Chikada Manager Automotive Lighting Engineering Control Dept. Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-ku Tokyo 153 Japan; Dear Mr. Chikada: This is in reply to your letter of January 11, 1985, to Mr. Vinson o this office, asking for a clarification of certain terminology relating to the definition of a standardized replaceable light source in Motor Vehicle Safety Standard No. 108.; We are aware of the problem underlying your question, i.e., that th standard contemplates testing of the bulb with its base but the photometrics specified are appropriate for the capsule portion alone. Our Rulemaking staff is reviewing this issue. The agency will inform you of the results of that review. If appropriate, the issue will be addressed through an appropriate interpretation or amendment of the standard.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3452OpenMr. Fred S. Barrington, Vice-President Engineering, Mid Bus Inc., 710 East Wayne Street, P.O. Box 1985, Lima, OH 45802; Mr. Fred S. Barrington Vice-President Engineering Mid Bus Inc. 710 East Wayne Street P.O. Box 1985 Lima OH 45802; Dear Mr. Barrington: This responds to your July 28, 1981, letter asking whether a portion o your school bus would be considered part of the sidewall or roof for purposes of complying with Standard No. 222, *School Bus Passenger Seating and Crash Protection*.; Paragraph S5.3.1.1 defines the head impact zone in which the hea protection requirements apply. The bus sidewall, windows and doors are exempted from complying with the requirements for head impact protection even if they fall within the head impact zone. The bus roof, on the other hand, must comply with the requirements if it falls within the zone. In the bus to which you refer in your letter, the bus wall and roof structure are not distinctly separated. You ask, therefore, where the roof stops and the sidewall begins.; The agency has stated by interpretation that the roof begins where th radius of curvature of the interior structure decreases sharply. From the sketch that you enclosed with your letter, it appears that the roof would begin at the point marked 'B'. Assuming that your diagram is correct, the side of the bus below point 'B' would be considered part of the bus sidewall and would not be required to comply with the head impact requirements.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4397OpenMr. Peter McIntosh, President, Stardor International Pty Ltd., Suite A803 The Towers, 1111 Crandon Blvd., Key Biscayne, FL 33149; Mr. Peter McIntosh President Stardor International Pty Ltd. Suite A803 The Towers 1111 Crandon Blvd. Key Biscayne FL 33149; Dear Mr. McIntosh: This is in reply to your recent undated letter to Taylor Vinson of thi office, requesting 'approval' of your Rear Ender stop lamp. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 *et seq*.) does not permit this agency to assure a manufacturer that its lighting equipment complies with all applicable requirements or to 'approve' any lighting equipment. Instead, section 114 of the Safety Act requires the manufacturer itself to certify that its lighting equipment complies with all applicable safety standards. Because of this statutory requirement, NHTSA cannot 'approve' your stop lamp or offer assurances that the stop lamp complies with all applicable safety standards. We can, however, state whether your lighting equipment appears to comply with the safety standards, based solely on the information set forth in your letter.; Your product is intended to be used as a center highmounted stop lamp One of the claims for the lamp made in the product literature that you enclosed is that 'Unlike many other rear brake lens' this one 'features a wider vision reflector....'; Paragraph S4.4 of Federal Motor Vehicle Safety Standard No. 108 *Lamps Reflective Devices, and Associated Equipment* prohibits combining the center highmounted stop lamp with any other lamp or reflective device. Because your lamp appears to incorporate a reflector with the lens it would not be acceptable as original equipment for passenger cars, or as replacement equipment for cars manufactured with a center highmounted lamp (generally those produced since September 1, 1985). You may be interested to know that we have expressed views on designs similar to concept to yours, but that did not appear to combine the lamp with another lamp or reflective device. I have enclosed an example of such an opinion letter.; There are no Federal restrictions applicable to use of your product o vehicles other than passenger cars, or on passenger cars manufactured before September 1, 1985, that were not equipped with a center highmounted stop lamp as original equipment. The acceptability of the device for these vehicles is determined by the laws of the States in which these vehicles would be registered and operated.; I hope that this answers your questions. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1195OpenMr. Robert G. Beaumont, President, Sebring Vanguard, Inc., P.O. Box 1479, Sebring Air Terminal, Sebring, FL 33870; Mr. Robert G. Beaumont President Sebring Vanguard Inc. P.O. Box 1479 Sebring Air Terminal Sebring FL 33870; Dear Mr. Beaumont: This is in reply to your letter of July 30, 1973, requesting furthe information about the relationship of the Federal motor vehicle safety regulations to the Vanguard electric vehicle.; You ask the following questions: >>>'1. Would prior commitments made before May 16, 1973, be sufficien for a temporary exemption?'<<<; Previously-existing commitments for parts that do not conform t systems covered by Federal motor vehicle safety standards may be presented to support the argument that compliance as of January 1, 1974, would cause substantial economic hardship. No temporary exemption has ever been requested on this basis alone, however, and whether an exemption would be granted solely on this basis would depend upon other facts in the case.; >>>'2. Can VANGUARD be classified as a multipurpose passenger vehicl and what relief would that give us from adhering to federal safety standards?'<<<; As you know, a 'multipurpose passenger vehicle' (MPV) is defined i part as a vehicle 'with special features for occasional off-road operation.' Intent for incidental off-road use is insufficient to qualify a passenger car as an MPV. The manufacturer makes the initial determination whether a vehicle is a passenger car or whether it is a MPV, incorporating 'special features' for occasional off-road operation not normally found on a passenger car. If he asks our views, we will provide them. If he does not, we are not precluded from questioning his vehicle categorization at a later date if it appears erroneous to us. The Vanguard appears to be a passenger car, but we would be willing to consider the matter further if you think it possesses unique off-road features.; >>>'3. How can we incorporate safety improvements in our vehicles prio to January 1, 1974, that may put us over the weight limit without violating law?'<<<; When you have completed a definitive review of your compliance proble areas you may apply for such exemptions as appear necessary. If safety improvements result in a vehicle weight that exceeds 1,000 pounds, you may legally market a vehicle if it has been exempted before January 1, 1974.; We appreciate your keeping us informed of your program with th Vanguard.; Sincerely, Lawrence. R. Schneider, Chief Counsel |
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ID: aiam3002OpenMr. Donald Beyer, National Service Manager, Vespa of America Corp., 355 Valley Drive, Brisbane, California 94005; Mr. Donald Beyer National Service Manager Vespa of America Corp. 355 Valley Drive Brisbane California 94005; Dear Mr. Beyer: I regret the delay in responding to your letter concerning the meanin of 'suppressed zero needle' as used in connection with Federal Motor Vehicle Safety Standard 127, *Speedometers and Odometers*. This term means simply that the lowest numbered speed on the speedometer scale may be greater than zero. Therefore, the lowest speed measured by the speedometer needle bay be greater than zero.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam4513OpenLisa Cappalli, Esquire Gager, Henry & Narkis One Exchange Place P.O. Box 2480 Waterbury, CT 06722-1791; Lisa Cappalli Esquire Gager Henry & Narkis One Exchange Place P.O. Box 2480 Waterbury CT 06722-1791; "Dear Ms. Cappalli: This is a response to your letter of last year t Ms. Tilghman of my staff, seeking an interpretation of Standard 125, Warning Devices (49 CFR 571.125). I apologize for the delay in this response. Specifically, you asked whether your client may proceed with the manufacture and distribution of a warning device, which you described further as an equilateral triangle with legs of 10 3/8 inches each. You also enclosed a diagram of the proposed device. Let me begin by explaining that your client does not need approval from this agency to manufacture or distribute this product. Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(1)(A), Safety Act) provides that, 'No person shall manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States, any ... item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect under this title unless it is in conformity with such standard ...' Section 114 of the Safety Act (15 U.S.C. 1403) establishes a certification process under which each manufacturer is required to certify that its products meet all applicable Federal safety standards. Therefore, your client, as a manufacturer of motor vehicle equipment, must certify that this product complies with all applicable standards. This agency has no authority under the Safety Act to approve, certify, or otherwise endorse any commercial product. The warning device your client plans to produce is motor vehicle equipment, within the meaning of section 102(4) of the Safety Act (15 U.S.C. 1391(4)). Thus, the question is whether this warning device complies with applicable safety standards. Paragraph S3 of Standard 125 reads as follows: 'This standard applies to devices, without self-contained energy sources, that are designed to be carried in motor vehicles and used to warn approaching traffic of the presence of a stopped vehicle, except for devices designed to be permanently affixed to the vehicle.' Since your client's product falls within this description, your client must certify that the product complies with all requirements of Standard 125. Section 108(b)(2) of the Safety Act (15 U.S.C. 1397(b)(2)) requires your client to exercise 'due care' in making any such certification. Based on the description in your letter, it does not appear that your client can certify that this device complies with one of the requirements in Standard 125. Paragraph S5.2.2 of Standard 125 states that, 'Each of the three sides of the triangular portion of the warning device shall be not less than 17 and not more than 22 inches long, and not less than 2 and not more than 3 inches wide.' According to your description, the sides of your client's proposed device would be only 10 3/8 inches long. Your client will have to increase the length of the sides in order to certify that this proposed warning device complies with Standard 125. We do not have enough information to offer any opinions as to whether this product appears to comply with the other requirements of Standard 125. You asked for information on how your client could obtain an exemption from Standard 125 if necessary. There is no provision in the Safety Act for exempting items of motor vehicle equipment from any applicable safety standard. However, section 157 of the Safety Act (15 U.S.C. 1417) gives this agency the authority to exempt equipment manufacturers from the requirement to give notice to owners and to remedy noncompliances with applicable standards, if the agency determines that the noncompliance is inconsequential as it relates to motor vehicle safety. The procedures for implementing this statutory authority are set forth in 49 CFR Part 556, Exemption for Inconsequential Defect or Noncompliance. Since your client plans to become a manufacturer subject to the requirements of the Safety Act, I am enclosing a copy of a general information sheet that briefly outlines the new manufacturer's responsibilities and explains how to get copies of relevant regulations. If you have some further questions or need further information on this subject, please contact Joan Tilghman of my staff at this address, or by telephone at (202) 366-2992. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam0803OpenMr. Sam Huff, Specifications Consultant, Associated General Contractors, Texas Highway-Heavy Branch, P. O. Box 2185, Austin, TX 78767; Mr. Sam Huff Specifications Consultant Associated General Contractors Texas Highway-Heavy Branch P. O. Box 2185 Austin TX 78767; Dear Mr. Huff: This is in reply to your letter of July 31, 1972, concerning work to b performed on new trucks. Your three questions are answered below.; You ask, 'What are the legal aspects of a road contractor doing th fifth-wheel work on a new truck?' The installation of a fifth wheel on a new vehicle would most likely make the installer a 'final-stage manufacturer' under NHTSA Certification regulations (49 CFR Part 567) and regulations governing 'Vehicles Manufactured in Two or More Stages' (49 CFR Part 568). Final-stage manufacturers bear the responsibility for certifying that the completed vehicle conforms to all applicable motor vehicle safety standards. The procedure for certifying is specified in the Certification regulations, copies of which are enclosed.; Your second question is, 'At what stage after purchase may a new truc be legally termed a used truck?' For our purposes, a used vehicle is any vehicle that has been purchased in good faith for a purpose other than resale (15 U.S.C. 1397(b)(1)).; Your last question is, 'Would the installation of extra lights o safety items be construed as final manufacturing?' The installation of readily attachable components, such as mirrors or tires, is not considered to be an activity which makes the installer a final-stage manufacturer. We are of the opinion that the same would be true regarding the installation of 'extra' lights (those not required pursuant to Motor vehicle Safety Standard No. 108, (49 CFR 571.108)). We cannot provide you with an opinion as to 'safety items' as this term is too general. However, assuming that you are referring to items not required by a motor vehicle safety standard, our answer would most likely be the same. The manufacturer should determine whether the component he installs affects to a significant extent either the configuration or purpose of the vehicle. If it does not, (we will accept a manufacturer's reasonable determination in this regard) then the installer would not be considered a final- stage manufacturer.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1711OpenMr. William D. Stokes, Laurence, Stokes & Neilan, Suite 805, Crystal Plaza 1, 2001 Jefferson Davis Highway, Arlington, VA 22202; Mr. William D. Stokes Laurence Stokes & Neilan Suite 805 Crystal Plaza 1 2001 Jefferson Davis Highway Arlington VA 22202; Dear Mr. Stokes: This is in reply to your letter of November 8, 1974, asking whethe manufacturers of pickup caps are required to certify these equipment items under the National Traffic and Motor Vehicle Safety Act.; There is no requirement at present that pickup caps be certified. TH certification label is a manufacturer's representation that a motor vehicle or item of motor vehicle equipment conforms to all applicable Federal motor vehicle safety standards, and there are no standards that presently apply to pickup caps.; Your client should be aware of a related requirement. Motor Vehicl Safety Standard No. 205, 'Glazing materials' (49 CFR S571.205), specifies requirements for glazing materials (glass and plastics for windows, doors, and interior partitions) used in motor vehicles and motor vehicle equipment, including pickup covers (essentially pickup caps as you describe them). Although applicable to the glazing material, the standard's effect under the National Traffic and Motor Vehicle Safety Act is that pickup caps must contain only glazing materials that meet the requirements of the standard.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam2994OpenMr. C. J. Goode, Chief Engineer, Leyland Cars, P.O. Box 2, Meteor Works, Lode Lane, Solihull, West Midlands B92 8NW, England; Mr. C. J. Goode Chief Engineer Leyland Cars P.O. Box 2 Meteor Works Lode Lane Solihull West Midlands B92 8NW England; Dear Mr. Goode:#I regret the delay in responding to your July 17, 1978 letter petitioning for reconsideration of Federal Motor Vehicle Safety Standard 101-80, *Controls and Displays*. You requested that the standard be amended to add three ISO symbols so that British Leyland could adopt common specifications in satisfaction of both FMVSS 101-80 and EEC directive 78/316. Your petition is in effect granted in part and is denied in part.#You asked that the ISO symbol (an illuminated light bulb) for the Master Lighting Switch be either substituted for Headlamp and Tail Lamp symbol (an illuminated headlamp) specified in Table 1 of FMVSS 101-80 or added as an option to that specified symbol. This aspect of your petition is denied. If a vehicle contains a master lighting control in addition to a headlamp and tail lamp control, the Master Lighting Switch symbol may be used for the master lighting control. We recognize, however, that most vehicles presently sold in this country have one control that operates all lights, including the headlamps and tail lamps. On vehicles having one control for all lights, the control must be identified by the Headlamp and Tail Lamp symbol. We believe that this is appropriate since the headlamps and tail lamps are the most important lights controlled by a master light control. Further, we believe that the Headlamp and Tail Lamp symbol is more easily recognized than the Master Lighting Switch symbol.#You also asked that the ISO symbol for the Manual Choke be added to Table 1 and the ISO symbol for the Brake System be added to Table 2. No amendment of the standard is necessary to permit your use of these two symbols since FMVSS 101-80 does not specify any requirements regarding symbols for those items. Amendment of the standard to require the use of those symbols would require a new proposal to be issued since such an amendment would be beyond the scope of the October 12, 1976, proposal which led to the June 26, 1978 final rule. Treating this part of your petition as a petition for rulemaking instead of a petition for reconsideration, we grant it. It should be understood that granting the petition does not necessarily mean that an amendment will ultimately be adopted.#Sincerely, Michael M. Finkelstein, Associate Administrator for Rulemaking; |
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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.