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: aiam2014OpenG. Buzzi-Ferraris, Pirelli Tire Corporation, 600 Third Avenue, New York, N.Y. 10016; G. Buzzi-Ferraris Pirelli Tire Corporation 600 Third Avenue New York N.Y. 10016; Dear Mr. Buzzi-Ferraris: #Please forgive the delay in responding t your letter of May 5, 1975, which inquired about the permissibility of iron-branding the letters 'N.A.' on the sidewall of certain passenger car tires to indicate that they are not adjustable under your warranty. #Federal Motor Vehicle Safety Standard No. 109, *New Pneumatic Tires-Passenger Cars*, Specifies labeling and performance requirements for such tires. The NHTSA has no objection to the provision of additional labeling information such as the 'N.A.' which you have suggested. However, the tire must continue to be capable of meeting the standard's performance requirements at the completion of the hot-branding process. #Sincerely, Frank Berndt, Acting Chief Counsel; |
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ID: aiam2501OpenMr. George I. Whiston, Mechanical Section Engineer, British Standards Institution, Head Office 2 Park Street, London W1A2BS; Mr. George I. Whiston Mechanical Section Engineer British Standards Institution Head Office 2 Park Street London W1A2BS; Dear Mr. Whiston: This responds to the British Standards Institution's December 2, 1976 request to know what constitutes 'first purchase of a new motor vehicle in good faith for purposes other than resale' as this phrase is used on (sic) S 108(b)(1) of the National Traffic and Motor Vehicle Safety Act (the Act) (15 U.S.C. S 1397(b)(1) and S 567.7 of NHTSA regulations (*Part 567--Certification*). You also ask to know the legal basis for any distinction between 'original equipment' and 'replacement equipment' as those terms are used in regulation of motor vehicles and equipment in the United States.; I can confirm your understanding of S 567.7 of our regulations, as se forth in the statements which you designate as '(a)' and '(b)'. With regard to statement '(b)', S 108(a)(2)(A) of the Act prohibits, except in the process of repair, a manufacturer, distributor, dealer, or repair business from knowingly rendering inoperative in whole or part, any device or element of design installed in a motor vehicle incompliance (sic) with an applicable standard. Thus a dealer could not make the sunroof alteration if he knew that installation rendered inoperative the minimum roof crush capabilities specified by Standard No. 216, *Roof Crush Resistance*.; Your statement designated '(c)' is not necessarily correct. The NHTSA' interpretation of the meaning of 'first purchase' relies substantially on the modifier 'in good faith.' Thus the agency evaluates the circumstances of the purchase with a view to whether or not there is an attempt to circumvent the requirements of law and applicable regulation. For example, when purchasers asked for disconnection of ignition interlock systems by dealers after contracting for the purchase of a vehicle, the agency required that bona fide physical delivery take place without an immediate return of the vehicle to the dealer for disconnection. As a practical matter, the new provision of the Act discussed above (S 108(a)(1)(A)) prohibits dealer action of this type in the future.; Since the 1974 amendments to the Act, there has been a distinctio between 'original equipment' and 'replacement equipment'. I have enclosed a copy of our proposal to implement this distinction for purposes of Federal regulation. I believe your question actually addresses the practices of the American Association of Motor Vehicle Administrators. You may wish to contact one or more of those organizations for an answer to your questions.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2151OpenMr. George H. Schildge, Exec. Vice President, Conti Rubber Products, 4900 Hannover Place, P.O. Box 1638, Fremont, California 94538; Mr. George H. Schildge Exec. Vice President Conti Rubber Products 4900 Hannover Place P.O. Box 1638 Fremont California 94538; Dear Mr. Schildge: This is in response to your October 29, 1975, letter concerning th applicability of Federal Motor Vehicle Safety Standard No. 119, *New Pneumatic Tires for Vehicles other than Passenger Cars*, to moped tires.; Mopeds are classified under 49 CFR 571.3 as 'motor-driven cycles', subcategory of 'motorcycles', for the purposes of the National Highway Traffic Safety Administration's regulations. Therefore, tires designed for use on mopeds are tires designed for use on motorcycles and, as such, are subject to Standard No. 119. The NHTSA is considering an amendment of Standard No. 119 which would modify the requirements applicable to such tires, and expects to issue a notice of proposed rulemaking on this subject on the near future.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4986OpenMr. Kevin J. Stoll Technical Advisor Russell Products, Inc. 21419 Protecta Drive Elkhart, IN 46516-9704; Mr. Kevin J. Stoll Technical Advisor Russell Products Inc. 21419 Protecta Drive Elkhart IN 46516-9704; "Dear Mr. Stoll: This responds to your letter of February 27, 1992, t Taylor Vinson of this Office asking several questions relating to center high-mounted stop lamps. Your questions are: '1. Are the LED (light emitting diode) being used for third brake light legal? If so, what are the specifications so that they can be used as a third brake light?' A center high-mounted stop lamp whose illumination is provided by LEDs is legal, provided that the light meets the photometric specifications for such lamp specified in Figure 10 of Motor Vehicle Safety Standard No. 108, and all other requirements. '2. a. Where are the truck manufacturers ie. GM, Ford, Dodge locating the third brake light on pickup trucks? b. What effect will this have on truck cap manufacturers and the dealer responsibility to the consumer? c. Can the dealer wire directly to the existing third brake light harness used to light up the factory third brake light?' With respect to (a), the center lamp may be installed at any point on the rear vertical centerline of pickup trucks. Because this requirement is not effective until September 1, 1993, we have no specific knowledge as to where the manufacturers of pickup trucks will locate the lamps. With respect to (b), NHTSA discussed the relationship of center high-mounted stoplamps to aftermarket slide-in campers or caps in the preamble to the final rule adopting the requirement. I enclose a copy of the rule (56 FR 16015) with our discussion highlighted on pages l6017 and 16018. After reading this material, if you have further questions regarding the effect on truck cap manufacturers and dealers, we shall be pleased to answer them. With respect to (c), we assume that the situation you envision is that a truck cap has been manufactured with a center stop lamp and the dealer is installing the cap on a pickup truck. If the cap is being permanently installed, the dealer may wire the cap's lamp directly to the existing center lamp light harness, as the cap lamp is intended as a surrogate for the original lamp. If the cap is removable, the dealer may also wire in the manner you discuss, provided that when the cap is removed (and the cap lamp disconnected) the original lamp will perform in conformance with Standard No. 108. The specific connections to be made should be done in accordance with the vehicle manufacturer's recommendations. '3. a. We have a customer that would like to mount a flush mounted third brake light in the rear glass window of a truck cap. This window is used also as the rear access door to get to the truck bed from the outside of the truck. b. This would allow the third brake light to be moveable and not stationery. If a consumer would have an object in the bed of the truck with the window in the open position, allowing for the third brake light to be left in an upward position and no longer viewed from the rear. Would this application be approved?' The agency has no authority to approve or disapprove specific designs. We can advise you as to whether designs appear to conform or not to conform with the applicable laws of our agency. Conformance with Standard No. 108 is determined with respect to the vehicle in its normal operating state. With respect to your question, this would be with the pickup cap window in its closed position. Thus, your design does not raise a question of conformance with Standard No. 108. '4. Could you please enter Russell Products, Inc. on your mailing lists for all future updated rulings on third brake lights passed or discussed at all committee meetings?' We do not maintain a mailing list of any sort. However, 'rulings' are not 'passed' at 'committee meetings' but are published in the Federal Register, initially as proposed rules affording a minimum of 45 days in which to comment. After evaluation of comments, a final rule may be published, with an effective date no earlier than 30 days after issuance. We believe it likely that any future proposals and amendments would be publicized, and that you would be likely to hear of them. There are no current plans to amend these requirements. Sincerely, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam0496OpenMr. Ed Baringer, Manager, Penn-Ohio Chapter, 25 East Boardman Street, Youngstown, OH 44503; Mr. Ed Baringer Manager Penn-Ohio Chapter 25 East Boardman Street Youngstown OH 44503; Dear Mr. Baringer: In your letter of November 23, 1971, you asked how your members coul make sure that the seat belts they install in their trucks conform to the applicable motor vehicle safety standards. As far as the belts themselves are concerned, each belt made after the seat belt standard (No. 209) became effective in 1967 is required to (sic) marked with the year of manufacture. So long as the belt bears a date after 1967, it will have had to conform to the seat belt standard and your members should use the date as a guide in purchasing belts.; The provision of anchorages for the belts is a somewhat more comple problem. A new truck - manufactured after July 1, 1971 - is required to have anchorages for lap belts at all seating positions (and, in some cases, anchorages for shoulder belts). Although older trucks were sometimes provided with anchorages, many were not, and for these you will have to follow the location and instructions of Standard No. 210 in order to comply with the Motor Carrier Safety Regulations. Although the Motor Carrier Safety Regulations do not establish strength requirements for anchorages, their strength should be of concern to you and in this area you may have to rely on the manufacturer, rather than the dealer, for advice on reinforcement of the vehicle structure.; Our legal staff is centralized in Washington and there are no fiel representatives of the agency who could assist you in matters relating to the standards. As much as we would like to send someone to address your group, the workload of the upcoming months prevents such a trip. However, we have found that many questions can be satisfactorily answered by letter. If your group could assemble a detailed list of questions, we will try to answer them as fully as possible.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3310OpenMr. William Tierney, 147 Conrad Morgan Way, Lothian, MD 20820; Mr. William Tierney 147 Conrad Morgan Way Lothian MD 20820; Dear Mr. Tierney: This is to follow-up on your phone conversation of June 10, 1980, wit Stephen Oesch of this office concerning the Federal requirements applicable to the installation of auxiliary fuel tanks in passenger cars.; I am enclosing a copy of a letter of interpretation the agency issue last August which discusses the general implication of such installations under Federal law. If after reviewing this material you have any additional questions, please contact Mr. Oesch.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4085OpenConfidential; Confidential; Dear Confidential: This is in response to your letter of June 21, 1985 requesting pursuant to 49 CFR Part 512, confidential treatment for your letter of that date and of the two attachments thereto.; Your request has been granted. NHTSA will treat your June 21, 198 letter and the attachments confidentially. Pursuant to a January 22, 1986 telephone conversation between (Confidential) and Heidi Lewis Coleman of my staff, our letter to you regarding this matter will be made publicly available to the extent indicated on the copy which is enclosed. Also enclosed is a copy of this confidentiality determination, which indicates the extent to which it will be made publicly available.; Sincerely, Kathleen DeMeter, Assistant Chief Counsel for General Law |
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ID: aiam3740OpenMr. Paul Scully, Vice President, Peterson Manufacturing Company, 4200 East 135th Street, Grandview, MO 64030; Mr. Paul Scully Vice President Peterson Manufacturing Company 4200 East 135th Street Grandview MO 64030; Dear Mr. Scully: This is in reply to your letter of July 22, 1983, to Mr. Cavey of thi agency.; With respect to paragraph S4.1.1.7 of Standard No. 108 *Lamps Reflective Devices, and Associated Equipment* you have stated your understanding that that paragraph applies only to turn signal lamps manufactured between January 1, 1972 and September 1, 1973, and that turn signal lamps must now comply with SAE Standard J588e, September 1970.; Paragraph S4.1.1.7 did allow vehicular compliance with SAE J588d as a option to J588e. J588d required that any turn signal lamp used on a vehicle whose overall width was 80 inches or more have a minimum of 12 square inches effective projected luminous lens area. On the other hand, SAE J588e requires a minimum of 8 square inches effective projected luminous lens area on all single compartment rear turn signal lamps, regardless of vehicle width. However, on vehicles 80 inches or more in overall width, two turn signal lamps or compartments per side may be mounted closer together than 22 inches provided each meets single compartment photometric requirements and each has a minimum effective projected luminous lens area of 12 square inches. Thus, your understanding is correct.; I would also point out that, pursuant to Section S4.7.1 of Standard No 108, the continued manufacture of turn signal lamps meeting J588d is permissible as replacement equipment for vehicles manufactured between January 1, 1972 and September 1, 1978.; Mr. Cavey has provided the copy of BMCS regulations which is enclosed. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2852OpenLawrence F. Henneberger, Esq., Robert W. Green, Esq., Messrs. Arent, Fox, Kintner, Plotkin & Kahn, 1815 H Street, N.W., Washington, DC 20006; Lawrence F. Henneberger Esq. Robert W. Green Esq. Messrs. Arent Fox Kintner Plotkin & Kahn 1815 H Street N.W. Washington DC 20006; Dear Messrs. Henneberger and Green: This is in reply to your letter of June 9, 1978, on behalf of you client, Jacobs Manufacturing Company ('Jacobs' herein).; Jacobs manufactures a diesel engine retarder system which 'produce significant deceleration of a large truck so equipped.' Jacobs believes that some means should be provided to warn following vehicles when a retarder is in use. It proposes to connect the retarder activation switch to the hazard warning system when a retarder is installed either as original equipment or as an aftermarket accessory. You have asked whether installation of the system would violate either 49 CFR 571.108, Motor Vehicle Safety Standard No. 108, or 15 U.S.C. 1397(a) (2) (A), section 108(a) (2) (A) of the National Traffic and Motor Vehicle Safety Act.; Paragraph S4.1.3 of Motor Vehicle Safety Standard No. 108 prohibits th installation of any device as original equipment that would impair the effectiveness of lighting equipment required by the standard. Paragraph S4.1.1 and Table I require trucks whose overall width is 80 inches or greater to be equipped with a hazard warning flasher system. The Jacobs device may not be installed if it would impair the effectiveness of the required hazard warning flasher system. The intended use of the Jacobs device is that it act as a warning of a decelerating vehicle in the roadway which may present a potential hazard. As such it augments the hazard warning system and, in our view, would tend to enhance rather than impair its effectiveness. Therefore, it may be installed as original equipment without violating S4.1.3. We have no provisions that would either permit or preclude its sale as an aftermarket device, and whether it is permissible as such is a matter to be determined by the laws of the States in which the truck is registered and operated, as well as those administered by the Bureau of Motor Carrier Safety, Federal Highway Administration.; Section 108(a) (2) (A) of the Act prohibits a manufacturer, amon others, from rendering inoperative, in whole or in part, any device installed in accordance with a Federal motor vehicle safety standard. Nothing in your letter indicates that the Jacobs device will affect the hazard warning signal flasher's ability to function at times when the Jacobs device is in operation, and therefore, it does not appear that its installation violates section 108(a) (2) (A).; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1287OpenMr. Erik Sundelin, Trelleborgs Gummifabriks Aktiebolag Fack, S-231 01 TRELLEBORG/Sweden; Mr. Erik Sundelin Trelleborgs Gummifabriks Aktiebolag Fack S-231 01 TRELLEBORG/Sweden; Dear Mr. Sundelin: #This is in reply to your letter of August 22, 1973 responding to our reply of June 26, 1973, to your letter of May 28, 1973. We informed you in the June 26 letter that labeling a passenger car tire, 'Max Load 1200 Lbs. At 36 psi,' would not be consistent with Motor Vehicle Safety Standard No. 109 because this label does not make it clear that 36 psi is the maximum permissible inflation pressure. In your letter of August 22 you state that you have already manufactured tires labeled in this manner, and ask whether such tires may be imported into the United States in their present form. #The answer to this question is no. As we have determined that this labeling does not conform to Standard No. 109, the tires in question cannot be imported into the United States unless the labeling is modified to conform the standard. #Sincerely, Richard B. Dyson, Assistant 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.