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
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ID: aiam1355OpenContinental Rubber Products, Inc., Minue Street, Carteret, New Jersey 07008; Continental Rubber Products Inc. Minue Street Carteret New Jersey 07008; Gentlemen: at the request of Continental Tire Company by letter of November 27 1973 (90316 - Ga/MAB/Sc), we are forwarding our response to their questions through you. They asked to know the lettering height to be used in compliance with the labeling requirements of Motor Vehicle Safety Standard No. 119.; The National HIghway Traffic Safety Administration is presentl considering the lettering height to be used for labeling required by Standard 119. Our decision as to lettering size will appear in the *Federal Register* as soon as possible after it has been made.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2980OpenMr. Mark E. Grayson, E. Grayson, Executive Assistant for Government Affairs, National Tire Dealers & Retreaders Association, Inc., 1343 L Street, N.W., Washington, DC 20005; Mr. Mark E. Grayson E. Grayson Executive Assistant for Government Affairs National Tire Dealers & Retreaders Association Inc. 1343 L Street N.W. Washington DC 20005; Dear Mr. Grayson: This is in response to your letter of March 2, 1979, in which yo request clarification of several points relating to the Uniform Tire Quality Grading (UTQG) Standards (49 CFR 575.104), and the record retention requirements applicable to tire retreaders.; You inquire first as to the obligations of tire dealers under the UTQ regulation. As explained more fully in our recent letter to Mr. Tony Hylton of your organization, the UTQG regulation places the responsibility for supplying tire grading information on vehicle and tire manufacturers and tire brand name owners. These parties must make their own arrangements with tire distributors and dealers to assure that the required tire grading information reaches tire purchasers.; You ask whether bias-ply tires manufactured abroad prior to April 1 1979, but imported into the United States after April 1, must be labeled in accordance with the requirements of paragraph (d)(1)(i)(B) of the UTQG regulation (49 CFR 575.104(d)(1)(i)(B)). Paragraph (d)(1)(i)(B), which becomes effective on April 1, 1979 for bias-ply tires, applies to bias- ply tires manufactured after that date. The date of manufacture rather than the date of importation is controlling in determining whether tires fall within the tread labeling requirements of the UTQG regulation.; You also ask whether tires to which the UTQG labeling requirement apply can be imported into the United States without the required tread labels, provided adequate labels are attached at the tires' point of sale. The purpose of the UTQG labeling requirements is to provide information to assist consumers in tire purchasing decisions. Therefore, the tread labeling requirements of the regulation would be satisfied if labels are attached at the dealership prior to the time the tires are offered for sale. However, manufacturers and brand name owners should be cautioned that they will be held responsible should the dealer incorrectly label the tires or neglect to attach the required labels.; Finally, you inquire whether manufacturers of retreaded tires mus retain tire registration records compiled pursuant to Part 574, *Tire Identification and Recordkeeping* (49 CFR Part 574), in view of the recent exemption of retreaders from the registration requirements of that part. While the registration requirements of Part 574 no longer apply to the sale of retreaded tires, section 574.7(d) (49 CFR 574.7(d)) nonetheless requires that previously compiled records on retreaded tires be maintained for a period of not less than three years from the date the information was recorded by the tire manufacturer or his designee.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam3692OpenMr. Anthony Lauro, President, VREDUSA, P.O. Box 279, Somerset, NJ 08873; Mr. Anthony Lauro President VREDUSA P.O. Box 279 Somerset NJ 08873; Dear Mr. Lauro: This responds to your recent letter asking if you can legally sel certain tires you have imported from the Netherlands. These truck tires have a DOT symbol on the sidewall but do not have a maximum load rating and corresponding inflation pressure labeled on the sidewall.; Under Federal law, these tires cannot be sold or otherwise introduce into interstate commerce because they do not comply with all requirements of Safety Standard No. 119, *New Pneumatic Tires for Motor Vehicles Other Than Passenger Cars* (49 CFR S571.119). Paragraph S6.5(d) of Standard No. 119 (copy enclosed) requires that a maximum load rating and corresponding inflation pressure be labeled on both sidewalls of each tire subject to the standard. The tires described in your letter plainly do not meet this requirement. Hence, the DOT symbol on those tires is misleading, since that symbol is supposed to be a manufacturer's certification that the tires comply with all requirements of Standard No. 119.; Section 108 of the National Traffic and Motor Vehicle Safety Act (1 U.S.C. 1397) specifies that no person shall sell or introduce into interstate commerce any item of motor vehicle equipment (which includes tires) unless the item is in conformity with all applicable safety standards. Section 109 of the Safety Act (15 U.S.C. 1398) sets forth a civil penalty of up to $1000 for each violation of section 108, and each of these nonconforming tires would be treated as a separate violation of section 108 if they were offered for sale or introduced into interstate commerce.; At this point, you have two legal courses of action open to you. Yo may have the tire manufacturer file a petition requesting an exemption from the noncompliance of these tires, arguing that the noncompliance is inconsequential as it relates to the safety of the tires. The procedures to be followed in filing a petition for an inconsequential noncompliance are set forth in the enclosed copy of 49 CFR Part 556, *Exemption for Inconsequential Defect or Noncompliance*. I cannot state at this time that the absence of maximum load information would be viewed as inconsequential, but we would certainly give full consideration to any petition the manufacturer might submit. If the petition were granted, you could sell these tires.; The other course of action available to you is to ship these tires bac to the manufacturer in the Netherlands and explain that they do not satisfy the requirements of Standard No. 119. I appreciate your efforts to ensure that you are complying with all applicable Federal regulations with respect to the sale of tires you import.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4157OpenMr. Francisco Dee Tan, President, FRG Industrial Corporation, 519 N. Alhambra Ave., #C, Monterey Park, CA 91754; Mr. Francisco Dee Tan President FRG Industrial Corporation 519 N. Alhambra Ave. #C Monterey Park CA 91754; Dear Mr. Tan: This is in reply to your letter of April 15, 1986, asking for ou approval of different types of rear stop lamps you wish to import.; The lighting devices depicted in the brochures that you enclosed ar not intended as original or replacement motor vehicle equipment, and therefore are not covered by Federal Motor Vehicle Safety Standard No. 108 *Lamps, Reflective Devices, and Associated Equipment*. If you are required to execute a Form HS-7 at the time of entry, the proper declaration is that provided by Box 1: the equipment was manufactured on a date when no Federal standards applied to it. In any event, this agency has no authority to approve or disapprove items of motor vehicle equipment since the National Traffic and Motor Vehicle Safety Act provides for self- certification by manufacturers of their products subject to Federal standards.; In the absence of Federal requirements, whether the devices you wish t import are legal for installation and use would be determinable under the laws of the individual States where the devices will be sold and installed.; I hope that this answers your question. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0817OpenMr. Russell E. MacCleery, Motor Vehicle Manufacturers Association, 320 New Center Building, Detroit, MI 48202; Mr. Russell E. MacCleery Motor Vehicle Manufacturers Association 320 New Center Building Detroit MI 48202; Dear Mr. MacCleery: This is in reply to your request of August 7, 1972, for the data use to support the conclusions we announced in Notice 20 of Docket 69-7 concerning the ignition interlock for the center front position and the ability of seat belt systems to meet a 60g, 3-millisecond injury criterion in 1975.; In evaluating the petitions for reconsideration of the center sea interlock requirements, we followed the techniques of cost/benefit analysis adopted in our earlier studies of passive restraints (see General Reference items 42, 43, and 99). The anticipated incremental benefit from an interlock at the center position was $9.70 per vehicle, which, when divided by the incremental cost of $7.00 supplied by Ford Motor Company (N16-69- 7-3), produced a favorable ratio of 1.4. Although the analysis was completed, it was used as a rough working paper and was not submitted to the docket. A typed draft of the analysis is being prepared for submission to the docket.; Although we decided to grant interim relief for belt systems from th 60g, 3-millisecond chest injury criterion, several manufacturers submitted data which indicated to us that their present systems were capable of meeting the criterion or that they were close enough that minor modifications would enable them to meet it. The data from your own organization (N13-69-7-16) showed that a number of cars were passing the criterion by comfortable margins. The Chrysler data, for example, revealed that in 9 tests no dummy recorded chest accelerations in excess of 50g's. Although General Motors, in its comment, submitted data on subcompacts which indicated a problem with chest accelerations, the data from their larger vehicles ranged between 38 and 52g's. (N13-69-7-20). Toyota also submitted test results with most accelerations in the range of 45-50g's, with only one test of a Corrolla appearing to show a marginal condition (N13-69-7-23).; From our research contracts, a number of sled tests have been conducte at Cornell Aeronautical Laboratory (General Reference No. 135), and most of these produced accelerations of between 30 and 50g's. From other sources have come data indicating that such improvements in belt design as the use of tear seams can produce significantly lower accelerations (see, e.g., General Reference items 161, 166, and 167).; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam3738OpenMr. Gary Richards, VIRACON, Inc., 800 Park Drive, Owatonna, MN 55060; Mr. Gary Richards VIRACON Inc. 800 Park Drive Owatonna MN 55060; Dear Mr. Richards: This is to follow-up on your phone conversation with Stephen Oesch o my staff concerning the agency's regulations and standards which would be applicable to a sunroof kit that you plan to manufacture as an item of aftermarket motor vehicle equipment. As I understand it, you only plan to manufacture the sun roof kit and have no plans to install the sun roof in vehicles. You were, however, interested in any regulations or standards affecting the installation of such a sun roof kit.; Safety Standard No. 205, *Glazing Materials*, specifies performance an location requirements for all glazing materials used on motor vehicles, whether as original equipment or as replacement (aftermarket) equipment. As a manufacturer or fabricator of glazing you would have to certify that the glazing used in your sun roof complies with all applicable requirements of the standard, a copy of which is enclosed.; Manufacturers of motor vehicle equipment also have specifi responsibilities under the National Traffic and Motor Vehicle Safety Act regarding safety-related defects in their products. Sections 151 *et* *seq*. of the Act requires manufacturers to notify purchasers about safety-related defects in their product and to remedy such defects without charge. A copy of the Act and the applicable defect regulations are enclosed. In addition, Part 556, *Manufacturer Identification*, requires vehicle and equipment manufacturers to provide the agency with certain information concerning themselves and the products they manufacture. A copy of Part 556 is enclosed.; If a sun roof is added to a vehicle before sale of the vehicle to it first purchaser, the vehicle alterer is required by Part 567 of our regulations to certify that the vehicle, as altered, complies with all applicable safety standards. A copy of Part 567 is enclosed. If the sun roof is added by a manufacturer, dealer, distributor, or repair shop after the sale of the vehicle to its first purchaser, the vehicle does not have to be recertified. Such businesses are, however, prohibited from knowingly rendering inoperative any device or element of design installed in a vehicle in compliance with any safety standard. Thus, for example, they would have to ensure that they do not install the sun roof in such a way that the vehicle no longer complies with Standard No. 216, *Roof Crush Resistance*, a copy of which is enclosed.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1705OpenMr. Murray Balmages, RSM Co., 602 Main Street, Gwynne Bldg., P.O. Box 1997, Cincinnati, Ohio 45201; Mr. Murray Balmages RSM Co. 602 Main Street Gwynne Bldg. P.O. Box 1997 Cincinnati Ohio 45201; Dear Mr. Balmages: #In reply to your letter of October 31, 1974, we d not have specifications for polyester tire cord. Our requirements for tires are directed only to the performance of manufactured tires, and do not deal with specifications for tire cord. #Yours truly, Richard B. Dyson, Acting Chief Counsel; |
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ID: aiam4507OpenIrving Gingold, Esq. 529 Nassau Road Roosevelt, NY 11575; Irving Gingold Esq. 529 Nassau Road Roosevelt NY 11575; Dear Mr. Gingold: This is in response to your letter of April 27, 1988 asking whether any of the Federal motor vehicle safety standards apply to an airport baggage conveyor. The answer is no. The National Traffic and Motor Vehicle Safety Act of 1966 ('Safety Act', 15 U.S.C. 1381 et seq.), authorizes this agency to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. Conversely, we have no authority to regulate vehicles that are not 'motor vehicles' or equipment that is not 'motor vehicle equipment.' Section 102(3) of the Safety Act (15 U.S.C. 1391(3)) defines a motor vehicle as any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. Under this definition, any vehicle intended and sold solely for off-road use is not considered a motor vehicle under the Safety Act, even if it is operationally capable of highway travel. We have long offered 'airport runway vehicles' as an example of vehicles that are not motor vehicles, because they are sold solely for off-road use. NHTSA has specifically stated that an airport baggage trailer is not a motor vehicle, in a July 11, 1983 letter to D.F. Landers. Since the airport baggage conveyor to which you referred in your letter is not a 'motor vehicle,' none of our safety standards or other regulations would apply to the vehicle. We are not aware of any other Federal agency that has established safety standards applicable to airport baggage conveyors. Sincerely, Erika Z. Jones Chief Counsel; |
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ID: aiam0544OpenMr. William S. Magenau, President, Chespeake Marine Products, Route 256, Deale, MD 20751; Mr. William S. Magenau President Chespeake Marine Products Route 256 Deale MD 20751; Dear Mr. Magenau: In your letter of September 21, 1972, you ask, 'are there any 'partia built' certification standards which would govern our operation as a boat trailer distributor?'; I enclose a copy of 49 CFR Part 567, *Certification*, and Part 568 *Vehicles Manufactured in Two or More Stages*, for your review as to their applicability to your operations. They apply to manufacturers who initiate or complete the manufacture of motor vehicles. They do not, however, impose an obligation upon a distributor of boat trailers who does not alter the vehicles he receives from a manufacture in a manner that affects compliance with applicable standards.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2579OpenMr. Paul Ideker, Lansdale, Carr & Baum, Advertising, Marketing & Management, 17622 Armstrong Avenue, Irvine, CA 92705; Mr. Paul Ideker Lansdale Carr & Baum Advertising Marketing & Management 17622 Armstrong Avenue Irvine CA 92705; Dear Mr. Ideker: This responds to your March 25, 1977, letter asking whether you proposed tire registration card to be used by your retail tire stores meets the requirements of 49 CFR Part 574, *Tire Identification and Recordkeeping*.; The National Highway Traffic Safety Administration (NHTSA) does no issue advance approvals of compliance with agency standards or regulations. The agency will, however, give an informal opinion as to whether your registration card appears to satisfy the requirements of the regulation.; The proposed card that you submitted is similar to the exampl presented in Figure 3 of Part 574. Accordingly, it appears to comply with most of the requirements of that regulation. The actual seller of the tires, however, is not identified on the form. Since Part 574.7 requires that the tire seller be identifiable to the tire manufacturer, the form should disclose that information. Naming only the corporate office is insufficient, since that does not readily identify the store through which the tire was sold. The NHTSA suggests that the actual seller's name and address be provided on the card as shown on Figure 3.; It is our understanding that the tire seller will forward the cards t you who will then forward the information to the manufacturer. This process is acceptable to the NHTSA as long as the information is forwarded to the manufacturer within the time frame specified in Part 574.8.; Sincerely, Frank A. Berndt, Acting 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.