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: aiam5333OpenLawrence A. Beyer, Esq. 674 Lake Road Webster, NY 14580; Lawrence A. Beyer Esq. 674 Lake Road Webster NY 14580; Dear Mr. Beyer: This is in reply to your FAX of February 14, 1994, t Taylor Vinson of this Office, relating to a policy of the Office of Vehicle Safety Compliance (OVSC) regarding importation of vehicles from Canada. Under this policy, and because of the close congruence of the Federal motor vehicle safety standards of both the U.S. and Canada, OVSC has, in essence, waived the requirement for bond and entry through the registered importer process if the Canadian vehicle is accompanied by a letter from the vehicle manufacturer stating that the vehicle was manufactured to comply with the U.S. standards, except for minor labelling variations. You state that this policy has been restricted to personally owned vehicles and does not allow 'importations of vehicles by corporations for their corporation's personal use.' Instead, these vehicles must be entered under bond and conformance verified or achieved by a registered importer. You state that you do not understand the distinction OVSC makes between individual personal use and corporate personal use. Under the Imported Vehicle Safety Compliance Act of 1988, as a general matter, a noncomplying vehicle may enter the United States permanently only if it is imported by a registered importer who brings it into compliance. However, an exception is made by 15 U.S.C. 1397(f)(1)(B) which allows importation by a person other than a registered importer if that person has a conformance contract with a registered importer and if the vehicle is imported 'for personal use, and not for purposes of resale, by any individual (other than an individual described in subsections (g) and (h)). . . .' The term 'individual' refers to a human being and not a corporate person. Therefore, the Act distinguishes both as to whether an importation is for personal use and whether the importer is an individual or a corporation. I hope that this answers your question. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam0131OpenMr. Donald S. Mortensen, Baycraft, 225 E. Lockhart, Coos Bay, OR 97420; Mr. Donald S. Mortensen Baycraft 225 E. Lockhart Coos Bay OR 97420; Dear Mr. Mortensen: Your letter of December 2, 1968, to Mr. William L. Hall, concernin safety glazing in canopies, has been referred to me for reply.; FHWA Ruling 68-1 clarified the requirement that slide-in campers mus comply with Standard 205 since they are items of motor vehicle equipment for use in motor vehicles. A copy of FHWA Ruling 68-1 is enclosed.; The same rationale applies to your canopies. Forward facing window must be laminated safety glass meeting the requirements of Test No. 26 of ASA Standard Z26.1-1966, July 15, 1966. Other windows may be AS1, 2, 3, 4, 5, 6, 7, 10, 11, 2-26, or 3-26.; Sincerely, Clue D. Ferguson, Director, Office of Standards o Crash-Injury Reduction, Motor Vehicle Safety Performance Service; |
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ID: aiam1409OpenMr. J.C. Eckhold, Director, Automotive Safety Office, Ford Motor Company, The American Road, Detroit, MI, 48121; Mr. J.C. Eckhold Director Automotive Safety Office Ford Motor Company The American Road Detroit MI 48121; Dear Mr. Eckhold: This is in reply to your letter of January 24, 1974, asking for a interpretation as to whether a rear lamp assembly design that Ford demonstrated to NHTSA representatives conforms to the location requirements of Standard No. 108. The assembly consists of three units which, from outboard to inboard, as a rear lighting assembly, comprise the tail lamp/stop lamp, backup lamp, and turn signal lamp.; Standard No. 108 specifies that stop lamps, tail lamps, and turn signa lamps be 'as far apart as practicable.' The standard does not specify a minimum separation distance of lamps, a maximum permissible location inboard, or location of one system relative to another. The determination of practicability in lamp spacing is to be made by the vehicle manufacturer, and the agency has generally afforded manufacturers some latitude in this interpretation.; Therefore, the configuration you have described and demonstrated woul not violate Standard No. 108. It should be noted, however, that it would be in conflict with the requirements for rear turn signals and stop lamps as proposed in Docket 69-19, Notice 3.; Sincerely, James B. Gregory, Administrator |
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ID: aiam3434OpenMr. W. D. Smith,, Acting Chief of Staff, United States Marine Corps, Marine Corps Logistics Base, Barstow, CA 92311; Mr. W. D. Smith Acting Chief of Staff United States Marine Corps Marine Corps Logistics Base Barstow CA 92311; Dear Mr. Smith: Your letter of June 23, 1981 was forwarded to this office for reply. The National Highway Traffic Safety Administration (NHTSA) has issued number of Federal Motor Vehicle Safety Standards (FMVSS) that are mandatory under the National Traffic and Motor Vehicle Safety Act for all motor vehicles operated on public streets and highways. Included in those FMVSS are some that specifically apply to vehicles classified by the manufacturer as school buses. The vehicle manufacturer's certification label, generally on the door pillar, or the door, or in the driver's compartment, identifies this classification of the vehicle (TYPE) and the date of manufacture, this information in turn identifies the FMVSS that are applicable to the vehicle. These FMVSS pre-empt all state standards that apply to the same area of performance or component and require that the state standard shall be identical with the FMVSS.; Under the provisions of the Highway Safety Act the NHTSA has als issued, eighteen Highway Safety Program Standards (HSPS). Number 17 of this group applies to Pupil Transportation Safety. A copy of the 18 HSPS is enclosed for your information and there are also more detailed manuals available for guidance. These 18 HSPS are not mandatory for Federal requirements and are for the purpose of providing uniform guidelines for the states to develop their own standards. Where a state has developed its own standards from such guidelines or as its needs may require, the state is fully in control of its laws and enforcement that is applicable. The color used for school buses, as an example, can be a mandatory state law requirement. Laws concerning the transportation of school children on California streets and highways are also the state's responsibility.; We have also enclosed a current copy of the three Acts administered b the NHTSA and a leaflet indicating where the detailed FMVSS can be obtained. A booklet briefly summarizing some of the FMVSS and Motor Vehicle Regulations is also enclosed.; We have forwarded your letter, plus the attachments of CH correspondence, to our office of Chief Counsel in Washington D.C. for their review and comment concerning exemptions or pre-emptions.; Joseph F. Zemaitis |
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ID: aiam1059OpenMr. Norman E. Salzman, General Manager, Fairmount Press, 1995 Jerome Avenue, Bronx, NY 10453; Mr. Norman E. Salzman General Manager Fairmount Press 1995 Jerome Avenue Bronx NY 10453; Dear Mr. Salzman: This is in reply to your recent letter concerning the use of a rubbe stamp referencing the Federal odometer law on bills of sale applicable to more than one vehicle.; It is our position that a bill of sale may be used to satisfy th odometer disclosure requirements, so long as it contains the information required by CFR 580.4. The rubber stamp whose impression you forwarded to us contains the initial paragraph of the form set out in section 580.6 of the regulation. It is therefore acceptable as a means of conforming the bill of sale to the disclosure requirements.; The regulations do not require a statement to be made separately fo each vehicle in a multi-vehicle transaction. So long as the identifying information specified in section 580.4 is provided with respect to each vehicle, and the odometer mileage for each vehicle is given, a single introductory statement in the form specified in section 580.6 will be sufficient to comply with the Federal requirements as to each vehicle.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3064OpenMr. Gerhard O. Waizmann, Porsche, 818 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Gerhard O. Waizmann Porsche 818 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Waizmann:#This is in response to your letter of May 25, 1979 requesting clarification of Federal Motor Vehicle Safety Standard No. 101- 80, *Controls and Displays*. You asked whether the rear window defogger switch, which emits a dim light for control location and a brighter light upon activation, is considered a control or a telltale.#Although the switch might be regarded as a control, telltale, or both, it is regulated as a control insofar as its illumination is concerned. Therefore, its illumination must be continuously variable as specified in S5.3.3 of the standard.#S5.3.3 provides that#>>>Each passenger car...manufactured with any control listed in S5.1 or in column 1 of Table 1, and each passenger car...with any display listed in S5.1 or in column 1 of Table 2, shall meet the requirements of this standard for the location, identification, and illumination of such control or display.<<<#The rear window defrosting and defogging system appears in the control list of S5.1 and in Table 1, but not in the display list of S5.1 or in Table 2. Therefore, the control illumination requirements of S5 apply to the defogging switch and the display illumination requirements do not.#If you have any further questions, please do not hesitate to write.#Sincerely, Frank Berndt, Chief Counsel; |
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ID: aiam2225OpenMr. Clarence J. Baudhuin, 24040 Killion Street, Woodland Hills, CA 91364; Mr. Clarence J. Baudhuin 24040 Killion Street Woodland Hills CA 91364; Dear Mr. Baudhuin: This is in response to your January 29, 1976, letter to Secretar Coleman, concerning problems with your 22 foot Executive 'MINI' Motorhome.; SS 567.4(g)93) and 567.5(a)(5) of 49 CFR Part 567, *Certification* provide that a motor vehicle's Gross Vehicle Weight Rating (GVWR) shall; >>>not be less than the sum of the unloaded vehicle weight, rated carg load, and 150 pounds times the vehicle's designated seating capacity.<<<; Your letter and its enclosures indicate that your vehicle's weight i 9180 pounds, its designated seating capacity is six, and the GVWR specified by Executive is 9000 pounds. From this information, there appears to be a violation by Executive of Part 567. In addition, the possibility that the rear axle may be overloaded under normal conditions of use may constitute a defect related to motor vehicle safety. I have forwarded your letter to our Office of Standards Enforcement for such further action as may be appropriate.; Please note that a final-stage manufacturer is not automaticall prohibited from certifying a GVWR that differs from that specified by the chassis manufacturer. For the purposes of the Federal motor vehicle safety standards and regulations, Executive is free to certify a lower GVWR, provided the above-cited constraint is observed.; The remaining questions presented in your letter are not matters ove which we have jurisdiction, and probably are most appropriately handled by a private attorney.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0218OpenMr. Melvin Hart, 1345 Fifth Avenue, New York, NY 10029; Mr. Melvin Hart 1345 Fifth Avenue New York NY 10029; Dear Mr. Hart: We have received your petition of March 10 for temporary exemption fro Federal Motor Vehicle Safety Standard No. 201 (Occupant Protection in Interior Impact). The petition raises several questions.; Standard No. 201 does not, as you appear to assume, pertain only t instrument panels. It also covers seat backs, interior compartment doors, sunvisors, and armrests. Please explain whether your are seeking an exemption from the entire Standard, or only from S3.1.; The comment on p. 6 of the petition, 'two of the standards loom highe than the rest as problems', raises the question whether you are still requesting an exemption from Federal Standard No. 103 (Defrosting and Defogging Systems). If so, then you should submit a supplemental petition containing the information we requested on February 19 in returning to you your petition of February 13.; The signature 'Melvin Hart Owner' does not fulfill the requirement (4 C.F.R. S 355.5(b)913)) that the application be signed 'by an officer of the petitioner and state his authority and area of responsibility'.; If you will explain the scope of your request for exemption fro Standard No. 201, whether an exemption from Standard No. 103 is still needed, and your corporate position with Transer, Inc. we shall consider your petition further.; In closing permit me to suggest that it would be to your advantage t submit as much information as possible on the safety characteristics of the T6.A, including relevant drawings and photographs. An exemption is based in part upon a finding that it is 'consistent with the public interest and the objectives of the National Traffic and Motor Vehicle Safety Act'. Since an exemption is, in effect, a license to manufacture motor vehicles, the Administrator must more (sic) data than the written assurances of a manufacturer that it will produce a 'safe' vehicle before he can find that the exemption is 'consistent with the public interest'. This is especially true concerning a new vehicle produced by a new company which has not manufactured motor vehicles before. If you would like to discuss the T6.A with our engineers we shall be happy to arrange such a meeting.; Sincerely, Lawrence R. Schneider, Assistant Chief Counsel fo Regulations; |
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ID: aiam3967OpenMr. Edward Maloney, 1302 Potter Road, Bellevue, NE 68005; Mr. Edward Maloney 1302 Potter Road Bellevue NE 68005; Dear Mr. Maloney: Thank you for your letter of April 17, 1985, concerning the safet belts in your 1984 Ford Tempo. You explained that Ford has offered to replace the safety belt buckle in your car and you asked if such an alteration is permissible under the Federal law. As discussed below, Ford can replace the buckle as long as the safety belt would continue to comply with our safety standard for safety belts.; Our agency has issued Federal Motor Vehicle Safety Standard No. 209 *Seat Belt Assemblies*, which sets performance and marking requirements for safety belts. All safety belts sold as items of original or aftermarket equipment must be certified as meeting Standard No. 209. The alteration or repair of items of safety equipment is affected by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act. That section provides, in part, that:; >>>No manufacturer, distributor, dealer or motor vehicle repai business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard....<<<; Thus, if a dealer alters a safety belt, the dealer must ensure that i is not rendering inoperative the belt's compliance with Standard No. 209.; I hope this information is of assistance. If you have any furthe questions, please let me know.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam2675OpenMr. Bruce Ducker, Attorney at Law, 1420 Larimer Square, Denver, CO 80202; Mr. Bruce Ducker Attorney at Law 1420 Larimer Square Denver CO 80202; Dear Mr. Ducker: This responds to your August 2, 1977, letter requesting copies o regulations issued pursuant to section 158(b) of the National Traffic and Motor Vehicle Safety Act of 1966 (as amended) (the Act) (15 U.S.C. 1381 *et seq.*).; I am enclosing a copy of Part 574, *Tire Identification an Recordkeeping* (Title 49 Code of Federal Regulations). This part details the recordkeeping requirements imposed by the agency upon tire manufacturers, distributors, dealers, and manufacturers of motor vehicles. In response to your question concerning the availability of customer lists, the agency has not issued any regulations on that point. You should note that these customer lists are retained by the manufacturer, not by the agency. Therefore, only the manufacturer would be in the position to divulge his customer lists. Should the agency obtain customer lists, they would not be disclosed unless disclosure was determined to be necessary to carry out the purpose of the Act as permitted by section 158(b).; Sincerely, Joseph J. Levin, Jr., 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.