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: aiam3649OpenMr. H. Miyazawa, Director, Automotive Lighting, Engineering Department, Stanley Electric Co., Ltd., 2-19-13, Nakameguro, Meguro-ku, Tokyo 153, Japan; Mr. H. Miyazawa Director Automotive Lighting Engineering Department Stanley Electric Co. Ltd. 2-19-13 Nakameguro Meguro-ku Tokyo 153 Japan; Dear Mr. Miyazawa: This is in reply to your letter of November 23, 1982, to Mr. Elliott o this agency asking whether you may distinguish between U.S. and Japanese-manufactured lighting equipment subject to Federal Standard No. 108 by marking the lenses 'U.S.A. DOT' and 'JAPAN DOT', rspectively (sic).; As you know, the National Highway Traffic Safety Administration has no adopted the SAE standard on equipment marking, J759c. This means that the only marking subject to Standard No. 108 is that which certifies compliance to all applicable Federal motor vehicle safety standards, the DOT symbol. We believe that the intended proximity of the words 'Japan DOT' in your Japanese- manufactured equipment might create the impression that Stanley was certifying compliance to the requirements of the Japanese Ministry of Transport, rather than to those of the U.S. Department of Transportation. Therefore, we suggest that you place the word 'Japan' at the end of the line rather than adjacent to the 'DOT' symbol.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4476OpenMr. Richard W. Ward Vice President K-D Lamp Company 1910 Elm Street Cincinnati, OH 45210; Mr. Richard W. Ward Vice President K-D Lamp Company 1910 Elm Street Cincinnati OH 45210; "Dear Mr. Ward: This is in reply to your letter of September 14, l988 asking for a clarification of Federal requirements for the minimum lens area for turn signal lamps and stop lamps. The understanding expressed in your letter is correct. The SAE materials for turn signal lamps and stop lamps for wide vehicles incorporated by reference in Table I apply to original equipment on vehicles currently being manufactured, and to equipment intended to replace such original equipment. These standards were expressly incorporated to supersede earlier versions of SAE standards for turn signal lamps and stop lamps. However, in recognition that original equipment lamps made to earlier SAE specifications might not be compatible with the electrical systems of vehicles designed to conform to later SAE specifications, the agency adopted paragraphs S4.l.l.6 and 4.l.l.7, allowing the continued manufacture for replacement purposes only, of turn signal lamps and stop lamps designed to conform to earlier specifications. Both sections incorporate in their text portions of the earlier SAE standards. Because the earlier specification for turn signal lamps, J588d, required an effective projected luminous area not less than 12 square inches for turn signal lamps on wide vehicles, this requirement is also specified in S4.1.1.7 for replacement lamps manufactured in conformance with J588d. In short, your interpretation is correct with respect to turn signal lamps manufactured for installation on vehicles whose overall width is 80 inches or more. Single compartment turn signal lamps designed to conform to SAE J588e need meet only a minimum luminous lens area of 8 square inches. But if a turn signal lamp is manufactured to replace a turn signal lamp that was designed to conform to SAE J588d, its minimum luminous lens area is 12 square inches. I hope this clarifies the matter for your customer. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam1224OpenMr. Jim Peters, Florida Department of Agriculture & Consumer Services, Tallahassee, FL 32304; Mr. Jim Peters Florida Department of Agriculture & Consumer Services Tallahassee FL 32304; Dear Mr. Peters: This is in response to your request of July 18, 1973, that the Nationa Highway Traffic Safety Administration undertake an investigation of possible odometer tampering on a vehicle purchased by Mr. Fulton Y. Roberts of Tallahassee.; There are no criminal penalties for violation of the odomete requirements of the Motor Vehicle Information and Cost Savings Act. Remedies for violation of the odometer requirements are of two types. In the case of repeated violations, the United States Attorney may seek injunctive relief against further violations. In the case of a violation which has already occurred, the remedy is a private civil action by the defrauded party. For this reason, the NHTSA does not normally investigate incidents such as this.; Mr. Roberts should be advised that he may be able to sue for $1,50 without proof of damages, or possibly more if he can prove damages.; Mr. Roberts may wish to consult an attorney in this matter. Th applicable provisions of the Act are enclosed.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3219OpenMr. David Williams, Box 4091, Wilmington, DE 19807; Mr. David Williams Box 4091 Wilmington DE 19807; Dear Mr. Williams: This responds to your February 12, 1980, letter asking severa questions about the applicability of Federal safety standards to an imported motor vehicle. In general, the National Highway Traffic Safety Administration requires all imported motor vehicles to comply with the safety standards in effect on the date of their importation.; In response to your first question, Standard No. 208, *Occupant Cras Protection*, requires each seating position in a passenger car to be equipped with a seat belt assembly as of January 1, 1968. Therefore, the rear bench seat of a 1972 passenger car was required by Federal regulations to have seat belts. If the vehicle to which you refer was imported without seat belts, the importer would have violated the National Traffic and Motor Vehicle Safety Act.; In your second question, you ask what standards apply to a vehicle tha was used by its manufacturer as a company vehicle and then sold as a used vehicle to an individual. The vehicle would be required to comply with the standards in effect on the date of its manufacture or, in the case of an import, on the date on which it was imported. In a related question, you ask whether some of the safety systems installed in a vehicle can be disconnected. An individual is permitted to disconnect safety systems on his or her own vehicle. However, no repair business, manufacturer, dealer, or distributor may render inoperative any safety device or element of design installed in a motor vehicle in compliance with the safety standards.; Finally, you ask whether a manufacturer may import into the country vehicle that does not comply with the safety standards. The answer to this question is no. An imported vehicle must comply with the safety standards in effect on the date of its importation into this country.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4026OpenMs. Janet L. Nedoba, Attorney at Law, 111 Addison, Elmhurst, IL 60126; Ms. Janet L. Nedoba Attorney at Law 111 Addison Elmhurst IL 60126; Dear Ms. Nedoba: Your letter of September 4, 1985, to the Consumer Product Safet Commission was forwarded to our agency for reply, since we issue safety standards for motor vehicles under the authority of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 *et seq*.). You asked if there are regulations that would apply to a safety belt used in a race car.; Our agency has issued Safety Standard No. 209, *Seat Belt Assemblies* which sets performance requirements for safety belts used in motor vehicles. A copy of the standard is enclosed. Section 102(3) of the Vehicle Safety Act (15 U.S.C. 1391(B)) defines a motor vehicle as 'any vehicle driven or drawn by mechanical power manufactured primarily for the public streets, roads, and highways,....' Whether a race car would be considered a motor vehicle covered by our standard would be determined by whether it was used on the street or whether it was intended and sold solely for off-road use. If the race car was manufactured for off-road (or non-public road) use, the standard would not apply.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4533OpenWilliam K. Baldwin, Sr. 14219 Decatur Drive Magalia, CA 95954; William K. Baldwin Sr. 14219 Decatur Drive Magalia CA 95954; "Dear Mr. Baldwin: This responds to your May 7, 1988 letter, concernin the 'Baldwin Rear-View Mirror Safety System.' You stated that this mirror system contains both a flat mirror of unit magnification and a convex mirror, and stated your belief that this mirror system 'offers the latest in technology and safety.' You requested that the National Highway Traffic Safety Administration (NHTSA) evaluate and approve your mirror system. We have no authority to approve any motor vehicles or motor vehicle equipment, as explained below. The National Traffic and Motor Vehicle Safety Act of 1966, as amended (the 'Safety Act') authorizes this agency to issue safety standards applicable to motor vehicles and items of motor vehicle equipment. The Safety Act also requires that these safety standards establish minimum levels of performance for vehicles or equipment. Once the necessary performance level has been established, vehicle or equipment manufacturers are free to choose any means they wish to achieve the required level of performance. In other words, the safety standards do not require the use of any particular manufacturer's product, the standards permit the use of any manufacturer's product that achieves the necessary performance level. Section 114 of the Safety Act (15 U.S.C. 1403) requires manufacturers to certify that each of its vehicles or items of motor vehicle equipment complies with all applicable safety standards. Because of this provision in the law, NHTSA cannot approve, endorse, or certify any motor vehicle or item of motor vehicle equipment. NHTSA has exercised its authority to establish performance requirements for new vehicles in Standard No. 111, Rearview Mirrors (49 CFR 571.111, copy enclosed). As you will see, Standard No. 111 establishes performance and location requirements for the rearview mirrors installed in any new vehicle. This means that vehicle manufacturers must certify that each of their new vehicles complies with the applicable requirements of Standard No. 111. Standard No. 111 does not apply to rearview mirrors as items of equipment. The effect of this is to place the certification responsibility for original equipment rearview mirror systems entirely on the vehicle manufacturer. You as the manufacturer of the mirror are not required to certify that your mirrors comply with Standard No. 111 or any other standard. With respect to your new mirror system, NHTSA has said in many previous interpretations that vehicle manufacturers may install mirror systems that combine flat and convex mirrors on their new vehicles, provided that the flat mirror portion by itself complies with the requirements of Standard No. 111 that are applicable to the vehicle type on which the mirror system is installed. Assuming that the flat mirror portion of your mirror system complies with the requirements of Standard No. 111 for the vehicle type on which it is to be installed, this new mirror system can legally be installed on new vehicles of that type. Please note that the requirements of Standard No. 111 do not apply to mirrors installed as aftermarket equipment. The only limitation on such installations is set forth in section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)). That section prohibits any manufacturer, distributor, dealer, or motor vehicle repair business from knowingly rendering inoperative any device or element of design installed on or in a motor vehicle in compliance with an applicable safety standard. The rearview mirror system in a vehicle is a device installed in compliance with Standard No. 111. If the installation of an aftermarket mirror system resulted in a vehicle no longer complying with Standard No. 111, a manufacturer, distributor, dealer, or repair business that removed a complying system and replaced it with the noncomplying system would have rendered inoperative a device (the mirror system) installed in the vehicle in compliance with Standard No. 111. Section 109 of the Safety Act (15 U.S.C. 1398) specifies a civil penalty of up to $1,000 for each violation of the 'render inoperative' provision. Again assuming that the flat mirror portion of your mirror system complies with the requirements of Standard No. 111 for the vehicle type on which it is to be installed, this new mirror system can legally be installed on used vehicles of that type. If your mirror system does not comply with the requirements of Standard No. 111 for a vehicle type, it cannot be installed on used vehicles of that type by any manufacturer, distributor, dealer, or repair business. Please note that the Safety Act does not establish any limitations on an individual vehicle owner's ability to alter his or her own vehicle. Under Federal law, individual owners can install any mirror system they want on their own vehicles, regardless of whether that mirror system renders inoperative the vehicle's compliance with the requirements of Standard No. 111. I hope this information is helpful. If you have any further questions, 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 Enclosures"; |
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ID: aiam0823OpenMr. Trevor Williams, Service Manager, Rolls-Royce, Inc., P.O. Box 189, Paramus, New Jersey 07652; Mr. Trevor Williams Service Manager Rolls-Royce Inc. P.O. Box 189 Paramus New Jersey 07652; Dear Mr. Williams: This is in reply to your letter of May 19, 1971, concerning th placement of vanity mirror in sun visors. We apologize for our delay in responding to your letter. The issues it raised, however, are of consequence to manufacturers other than Rolls-Royce, and concerned basic matters of interpretation of Standard No. 201 which have only recently been resolved.; The National Highway Traffic Safety Administration has determined tha paragraph S3.4.1 of Standard No. 201 does not prohibit the installation by manufacturers of vanity mirrors on sun visors. Consequently, manufacturers are free to incorporate such mirrors into or onto sun visors, including mirror that are recessed into the surface of the visor as in the sample you enclosed.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam1731OpenMr. George McDonald, Engineering Manager, Tridon Limited, Box 5029, Burlington, Ontario, Canada; Mr. George McDonald Engineering Manager Tridon Limited Box 5029 Burlington Ontario Canada; Dear Mr. McDonald: This is in reply to your letter of December 6, 1974 to this offic requesting clarification of Motor Vehicle Safety Standard No. 108.; You are correct in your interpretations numbered 1, 2, and 3. Th applicable SAE Standard or Recommended Practice for a turn signal flasher is J590b, October 1965, and for a vehicular hazard warning signal flasher is J945, February 1966. The footnote 'See S4.4.2' is in error and should be deleted.; You are incorrect in your interpretation No. 4. Paragraph S4.4.1 allow use of a combination turn signal flasher-hazard warning signal flasher if the requirements of both J590b and J945 are met. The correct testing sequence is as follows: (1) for performance as a turn signal flasher, (2) for performance as a hazard warning signal flasher, (3) for durability as a turn signal flasher, and (4) for durability as a hazard warning signal flasher.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0989OpenMr. Orin D. Miner, P.O. Box 138, Palmyra, Wisconsin 53156; Mr. Orin D. Miner P.O. Box 138 Palmyra Wisconsin 53156; Dear Mr. Miner: Contact 6 of Milwaukee, Wisconsin has sent us a copy of your lette asking that we respond to your questions.; In your letter you inquire as to the distribution of fines collecte from tire manufacturers as a result of their manufacturing tires that do not comply with the requirements of the Federal standard for passenger car tires (Standard No. 109).; Monies collected as settlement offers are transmitted to the genera funds of the United States Treasury.; The Federal Motor Vehicle Safety Standard, including the passenger ca tire standard, are minimum standards vehicle manufacturers and equipment manufacturers are required to meet. They are issued to give assurance that if the product in question meets the standards the public will have some protection against unreasonable risk of death or injury.; In addition to the question of civil penalties, manufacturers o non-conforming vehicles or tires are usually required to issue a defect notification and are urged to replace the defective equipment. Your complaint does not appear to be concerned with a safety related problem but rather with tires that you believe have not given you adequate treadwear. This is not area covered by existing standards, however, this agency has under consideration a quality grading regulation which would include grading requirements for the treadwear life of each tire manufactured after a given date.; Concerning your recommendation that Federal inspectors be placed i tire manufacturers' plants, has been considered at various times and the agency's present thinking is that the cost and manpower involved would not warrant this course of action.; Thank you for your interest in auto safety and your view in this area. Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4163OpenMr. Robert E. Mileham, Operations Manager, Durnell Engineering, Inc., Highway 4 South, Emmetsburg, IA 50536; Mr. Robert E. Mileham Operations Manager Durnell Engineering Inc. Highway 4 South Emmetsburg IA 50536; Dear Mr. Mileham: Thank you for your letter of September 18, 1985, regarding th trailer-mounted aerial personnel left or 'cherry picker' which your company manufactures. I regret the delay in responding to your letter.; You ask whether a vehicle identification number (VIN) is required o these trailers. You state that the sole purpose of the trailer is to take the aerial lift to and from a job site and estimate that the trailer will not spend more than 10% to 15% of its time traveling on the highway.; The National Traffic and Motor Vehicle Safety Act provides tha vehicles which fall within the statutory definition of the term 'motor vehicle' must comply with applicable safety standards. That definition includes vehicles 'manufactured primarily for use on the public streets, roads, and highways.' (15 U.S.C. 1391(3)). The agency has taken the position that this definition does not encompass mobile construction equipment which uses the highways only to move between job sites, whose job sites are normally located off the public roads, 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, not the primary purpose for which the vehicle is manufactured.; The information in the brochure enclosed with your letter indicate that the job site of your cherry picker is typically in the streets, not off the road. Based on that information, it appears that your cherry picker may spend virtually its entire operating life on public roads. When a vehicle frequently uses the highway going to and from job sites, and its job site is frequently on the road, the agency's position is that the vehicle is a 'motor vehicle.' Therefore, these trailers are required to comply with Standard No. 115, *Vehicle Identification Number-- Basic Requirements*, and other standards applicable to trailers.; You also ask in your letter if these trailers could be considered th same as mobile air compressors, mobile cement mixers, or mobile generators, which the state of Iowa apparently licenses as 'Special Mobile Equipment,' not requiring a VIN. Whether a state requires a VIN on your trailer lifts, for purposes of licensing or registration, is not determinative of Federal regulatory questions. This agency has taken the position that mobile cement mixers, for example, are motor vehicles because of their use of the public roadways in traveling from job site to job site and their typically short time at any particular site. Therefore, they must comply with Standard No. 115 as well as other Federal motor vehicle safety standards.; I hope this information is helpful to you. Sincerely, Erika Z. Jones, Chief Counsel |
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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.