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: aiam5116OpenMr. David H. B. Lee President, Lee Family, Inc. 701 East 30th Hutchinson, KS 67502; Mr. David H. B. Lee President Lee Family Inc. 701 East 30th Hutchinson KS 67502; "Dear Mr. Lee: This responds to your letter of December 29, 1992, wit respect to a 'Third Brake Light Conditions Sensor', for which you have requested a review and testing. You have also asked for our comments and advice on the sale and promotion of this product. We assume that you would like to sell it in the aftermarket to vehicle owners. We have reviewed the videotape you enclosed, and are able to advise you on this basis. The tape shows that the device is intended for installation by the owner of the vehicle, and, when installed, causes the center highmounted brake lamp to flash in proportion to braking effort (i.e., a panic or quick stop produces a higher flash rate than a stop made at a slower vehicle deceleration). Motor vehicle lighting in the United States is subject to both Federal and State requirements. The National Traffic and Motor Vehicle Safety Act and Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment are the Federal requirements to which I refer. Standard No. 108 prescribes requirements for center highmounted stop lamps that must be followed by the manufacturer of the vehicle, and met at the time the vehicle is sold by the dealer to its first owner. One of these requirements is that the center highmounted stop lamp be steady burning when it is in use. Because the Sensor creates a flashing light, a vehicle manufacturer would not be able to use it as original equipment on a vehicle subject to Standard No. 108's requirements for center lamps. These vehicles are passenger cars manufactured on and after September 1, 1985, and light trucks and vans manufactured on and after September 1, 1993. The Safety Act governs modifications to vehicles after their initial sale. This Act does not prohibit a vehicle owner from modifications that affect compliance with Standard No. 108 (or any other Federal motor vehicle safety standard). Thus, a vehicle owner may install the Sensor without violation of Federal requirements. However, we interpret the Safety Act as prohibiting the installation of the Sensor by a manufacturer, dealer, distributor, or motor vehicle repair business. Under the Act, these persons shall not 'render inoperative, in whole or in part, any device or element of design installed in accordance with a Federal motor vehicle safety standard.' In our view, this forbids the installation of equipment that would take a vehicle out of compliance with a Federal motor vehicle safety standard. However, the Act does not forbid the sale of componentry such as the Sensor which creates a noncompliance once it is installed. In summary, under Federal law, any person may sell your device, but only a person other than a manufacturer, dealer, distributor, or motor vehicle repair business may install it. We are unable to advise you as to whether the laws of any State prohibit the use of a flashing center highmounted stop lamp, and recommend that you consult the American Association of Motor Vehicle Administrators for an opinion. Its address is 4600 Wilson Boulevard, Arlington, Va. 22203. We are returning your videotape and sample Sensors. Sincerely, Paul Jackson Rice Chief Counsel Enclosures"; |
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ID: aiam5403OpenMr. Dietmar K. Haenchen Manager, Vehicle Regulations Volkswagen of America, Inc. 3800 Hamlin Road Auburn Hills, MI 48326; Mr. Dietmar K. Haenchen Manager Vehicle Regulations Volkswagen of America Inc. 3800 Hamlin Road Auburn Hills MI 48326; "Dear Mr. Haenchen: This responds to your request for an interpretatio of marking requirements in 49 CFR part 541 Federal Motor Vehicle Theft Prevention Standard for high theft vehicle lines' replacement parts. The answer to both of your questions is VW is still required to mark the replacement parts in question. In your letter, you explained that the Volkswagen Corrado line, a high theft line, was parts marked (pursuant to 49 CFR part 541) in model years 1990 through 1994. For model year 1995, NHTSA granted an exemption from parts marking for the Corrado line, based on the inclusion of an approved antitheft device as standard equipment on all models in the Corrado line. (58 FR 28434, May 13, 1993). However, you informed us in your letter that the Corrado will not be sold in the United States for MY 1995. Your first question asks whether replacement parts for the Corrado line are exempted from the parts marking requirements of part 541. The answer is no. Section 543.7(d) specifies that part 543 exemptions apply only to lines that are the subject of the grant, and are equipped with the antitheft device on which the line's exemption was based. You inform us that the Corrado will not be offered for sale in the U.S. in MY 1995. If the Corrado will not be offered for sale in this country, then no Corrrados sold in the U.S. will be equipped with the approved antitheft device. If no Corrado is so equipped, the part 543 exemption would not apply to the Corrado line. Thus, Volkswagen would be required to continue to mark any Corrado replacement parts, subject to part 541, offered for sale in the U.S. In your letter, you cited an October 12, 1989 NHTSA interpretation letter to Saab-Scania of America to support your position that the Corrado's replacement parts need not continue to be marked. We do not believe that the letter to Saab supports your position. Saab received an exemption from parts marking for the Saab 9000 for the 1989 model year, and asked NHTSA to clarify the scope of the part 543 exemption. On page two of the letter to Saab, NHTSA stated that Saab was free to discontinue marking of original equipment and replacement parts for the Saab 9000 as soon as the part 543 exemption took effect, 'provided that Saab actually installed the antitheft device described in its petition...' The letter to Saab establishes that if it does not install the antitheft device on the exempted line, a manufacturer is not free to discontinue marking replacement parts on the line. Your second question was whether replacement parts marking may be terminated at some point after a high theft line subject to parts marking, is no longer produced. The answer is no. This issue was addressed in the final rule establishing 49 CFR part 541 (50 FR 43166, October 25, 1985): Once a line is selected as a high theft line, each covered major replacement part designed for use on that line must be identified as a replacement part. That requirement remains in effect as long as those replacement parts are produced. (50 FR 43178). Thus, as long as replacement parts are produced for a high theft line subject to parts marking, the replacement parts must continue to be marked. I hope that this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam1913OpenMr. Danny J. Lanzdorf, Supervising Engineer, Oshkosh Truck Corporation, P.O. Box 560, Oshkosh, WI 54901; Mr. Danny J. Lanzdorf Supervising Engineer Oshkosh Truck Corporation P.O. Box 560 Oshkosh WI 54901; Dear Mr. Lanzdorf: This responds to your April 1, 1975, request for confirmation that th emergency braking stopping distance requirements in S5.7.2.3 of Standard No. 121, *Air brake systems*, specify that, when stopped six times for each configuration of weight and speed specified in S5.3.1.1 on a road surface with a skid number of 75 (with a single failure introduced in the service brake system), the vehicle must stop at least once within the distances specified in Column 3 of Table II and no part of the vehicle must leave the 12-foot roadway. You also request confirmation that modulation of the service brake control during the stop is not prohibited.; With certain exceptions, the statements in your letter are correct Your interpretation only sets out the basic stopping distance requirements for those vehicles which the manufacturer has chosen to make conform to S5.7.2 of the standard. Thus, your interpretation does not include any of the requirements of the emergency braking capability option found in S5.7.1. Additionally, your interpretation does not include the requirements for a truck-tractor at unloaded vehicle weight plus 500 pounds, or for the trucks and buses which qualify for the interim requirements of S5.7.2.3.1 and S5.7.2.3.2.; Section S5.7.2 does not prohibit modulation of the emergency brakin capability, and modulation by means of the service brake control is therefore permissible.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0601OpenMr. R. W. Bond, Project Engineer, K D Lamp Company, 1910 Elm Street, Cincinnati, OH, 45210; Mr. R. W. Bond Project Engineer K D Lamp Company 1910 Elm Street Cincinnati OH 45210; Dear Mr. Bond: This is in reply to your letters of December 2, 1971, and February 11 1972, concerning Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.' You ask whether the standard is applicable to interior lighting of any material, either plastic or otherwise. Under the present language of the standard, interior lighting would only be subject to it if the manufacturer has, as specified in S4.1 of the standard, designed it to 'absorb energy on contact by occupants in the event of a crash.' The NHTSA is presently reviewing the necessity of this requirement, and it may be revised in the near future.; We regret the delay in responding to your letter. Your truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3884OpenMr. John L. O'Connell, Department of Motor Vehicles, State of Connecticut, State Street, Wethersfield, CT 06109; Mr. John L. O'Connell Department of Motor Vehicles State of Connecticut State Street Wethersfield CT 06109; Dear Mr. O'Connell: This responds to your October 15, 1984 letter to the National Highwa Traffic Safety Administration (NHTSA) asking about an emergency door which is installed on a school bus in addition to the emergency exits required by Federal Motor Vehicle Safety Standard (FMVSS) No. 217, *Bus Window Retention and Release*.; Your first question asked whether this additional emergency exit i required to comply with Standard No. 217. In particular, you asked about the labeling requirements. FMVSS No. 217 requires that additional exits on school buses which are intended as emergency exits must comply with the emergency exit requirements applicable to exits in buses other than school buses. These additional emergency exits would be required to be labeled in accordance with the requirements for exits in non-school buses.; Your second question asked whether the door may be sealed shut. Yo also asked whether sealing the door would have any effect on the compliance of the bus with FMVSS No. 221, *School Bus Body Joint Strength*.; The answer to this question depends on who seals the door, and whe this work is performed. As you probably know, NHTSA does not have the authority to prohibit an owner, such as a school, from modifying its own vehicle. A school may modify its own vehicle in any manner without assuring that the vehicle remains in compliance with motor vehicle safety standards. Of course, it may be more difficult to insure a vehicle which does not conform to the safety standards. The school can also expose itself to increased liability in the event that one of their noncomplying vehicles is involved in an accident.; After the vehicle is sold to its first purchaser, manufacturers dealers, distributors or repair businesses are prohibited from knowingly rendering inoperative any device or element of design installed on or in a vehicle in compliance with an applicable motor vehicle safety standard. The additional door could be sealed by a manufacturer or repair-type business as long as there were sufficient other emergency exits available on the vehicle so that it remains in compliance with the requirements of Standard No. 217. Moreover, if the door were sealed after the vehicle's first sale, FMVSS No. 221 would not be a factor. This is because doors are not considered 'body panel joints' subject to the requirements of the standard. Since the additional door was not regulated by Standard No. 221, there would be no rendering inoperative of the compliance of the door with that standard.; If you decide to seal the emergency exit shut, we would encourage yo to remove the labels to avoid possible confusion in the event of an accident.; If the door was made inoperable prior to the vehicle's first sale FMVSS No. 221 would be a factor. This is because the person sealing the door is an 'alterer,' and must attach a label indicating compliance of the altered vehicle with the standards. When the door is sealed, it becomes part of the bus wall structure. As such, any joints on the door that would fall within the ambit of Standard No. 221 would be required to comply with that standard. The alterer would also be required to remove any labels and operating instructions from the exit which was sealed, since labels indicating that a door can be used as an emergency exit when in fact the door is inoperative would not conform to Standard No. 217.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5053OpenMr. Takashi Odaira Chief Representative Emissions & Safety Isuzu Technical Center of America, Inc. 46401 Commerce Center Drive Plymouth, MI 48170; Mr. Takashi Odaira Chief Representative Emissions & Safety Isuzu Technical Center of America Inc. 46401 Commerce Center Drive Plymouth MI 48170; Dear Mr. Odaira: This responds to your letter asking about the sid door strength test procedures of Standard No. 214, Side Impact Protection, as they apply to a certain pickup truck design. You described three alternative methods of fixing the vehicle in position and asked whether they are consistent with the standard's test procedure. By way of background information, the National Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles and equipment meet applicable requirements. The following represents our opinion based on the facts provided in your letter. S4(a) of Standard No. 214 sets forth the following procedures for fixing a vehicle in position for the quasi-static side door strength test: Place the sill of the side of the vehicle opposite to the side being tested against a rigid unyielding vertical surface. Fix the vehicle rigidly in position by means of tiedown attachments located at or forward of the front wheel centerline and at or rearward of the rear wheel centerline. (Emphasis added.) The side door strength test is then conducted by applying a loading device to the outer surface of the door, until the loading device travels 18 inches. See S4(d). You asked about these procedures in connection with a certain pickup truck design, which can be described as follows. The cab of the truck is attached to the frame by means of flexible rubber mountings. The rear body is installed separately on the frame. The cab of the truck is over the front wheels, and the rear body is over the rear wheels. You requested our comments on three alternative methods of testing the pickup truck at issue. The first would involve fixing the frame of the vehicle at or forward of, and at or rearward of, the front and real wheel centerlines. You stated, however, that the rear portion of the cab would not be rigidly fixed by this method, and that the application of the Standard No. 214 loading device would result in the stretching of the cab's rubber mountings and upward tilting of the cab as a whole. Your second alternative would involve adding a third fixing of the vehicle, in addition to the front and rear fixings of Alternative 1. This additional fixing would be at the rear of the cab, on both sides. You indicated that this would permit the side door strength test to be conducted without tilting the vehicle, but that the relative cab to frame fixing would not be the same as on an actual vehicle. Your third alternative would involve fixing the cab alone to a test fixture, at three locations. You stated that a problem with this method may be that the cab itself, and not the vehicle, is tested. In considering how the Standard No. 214 quasi-static test should be conducted for a particular vehicle, it is important to bear in mind that the purpose of the test is to measure the crush resistance of a side door. The agency is not measuring the extent to which a vehicle's suspension or other design features permit the vehicle to tilt when specified loads are applied. In order to measure the crush resistance of a door in a test, it is necessary that the vehicle be fixed rigidly in position. Otherwise, the application of a load to the side door could simply result in movement of the vehicle as a whole. Standard No. 214's test procedure was developed initially for cars. As noted by your letter, the combination of tying the vehicle down at or forward of, and at or rearward of, the front and rear wheel centerlines and placing the sill of the side of the vehicle opposite to the side being tested against a rigid unyielding vertical surface is sufficient to rigidly fix a passenger car in position for test purposes. Your letter raises the issue of how the Standard No. 214 test should be conducted if the specified procedure does not result in a particular vehicle, such as one with a divided body, being rigidly fixed in position. For purposes of compliance testing, NHTSA would take the following actions. First, the agency would examine whether the procedure set forth in S4(a) would result in the vehicle being rigidly fixed in position. This could involve considering various tiedown arrangements within the areas specified by S4(a). If the agency determined that the procedure was not sufficient to rigidly fix a vehicle in position, e.g., the entire cab of a pickup truck would tilt upward during a test, it would then follow the specified procedure but also add an additional tiedown attachment as necessary to rigidly fix the vehicle in position. In making this additional attachment, the agency would take care to ensure that the attachment did not interfere with the side door strength test. I can offer the following comments on the three alternative test methods you described. NHTSA would not follow the Alternative 1 test procedure since the vehicle would not be rigidly fixed in position under that procedure. The agency would also not follow the Alternative 3 test procedure since it does not include one of the tiedown arrangements specified by S4(a). The agency might follow an approach along the lines of Alternative 2, assuming that it determined that the S4(a) procedure was not sufficient to rigidly fix the vehicle in position. I hope you find this information helpful. If you have any other questions, please contact Edward Glancy of my staff at this address or by phone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam2796OpenMr. Tom Caine, Esq., The Goodyear Tire & Rubber Company, Akron, Ohio 44316; Mr. Tom Caine Esq. The Goodyear Tire & Rubber Company Akron Ohio 44316; Dear Mr. Caine: This responds to your March 16, 1978, letter asking about th responsibility for compliance with the Federal motor vehicle safety standards when previously certified tires are modified by the addition of white sidewalls.; In your first question, you ask whether the person who modifies th tire must recertify it for compliance with safety requirements. The answer to your question is no. A modifier of a tire is not considered a manufacturer as that term is defined in the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 *et seq.*). A modifier's status is analogous to that of an alterer of a previously certified motor vehicle, there are no labeling or certification requirements for alterers of motor vehicle equipment. Persons who modify previously certified motor vehicle equipment are required to ensure that their modification does not render inoperative any device or element of design installed in compliance with a safety standard.; Since the modifier of previously certified motor vehicle tires has n labeling or certification requirements, the answer to your second question whether it would be required to obtain a manufacturer's identification code mark is no. Only a manufacturer or retreader of motor vehicle tires need obtain such identification marks.; In you final question, you ask who would be responsible for th registration of these modified tires. The original tire manufacturer would be required to conduct the tire registration program. Your assert that this might cause confusion in tire recalls since manufacturers might indicate that blackwall tires are being recalled when, in fact, some whitewall would be included. Our regulation requires that tires be identified in a recall by their serial number. We are not aware of any instance where recalled tires serial have been additionally identified as 'blackwall' by the manufacturers. Thus, although the problem you describe could conceivably occur, we at this time have no basis for viewing it as a real threat to effective recall campaigns.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0251OpenMr. Lawrence R. Walders, Tanaka and Walders, Federal Bar Building West, 1819 H Street, N.W., Washington, D.C. 20006; Mr. Lawrence R. Walders Tanaka and Walders Federal Bar Building West 1819 H Street N.W. Washington D.C. 20006; Dear Mr. Walders: This will acknowledge your letter of July 27, 1970 to the Nationa Highway Safety Bureau requesting an interpretation of Federal Motor Vehicle Safety Standard No. 110.; You are correct in your statement that no formal petition for rul making action is necessary for tire and rim combination cited within the references of S3 of Standard No. 109.; Concerning your question on 'approval equivalent rim', we offer th following. The policy of the bureau in 1967 at the time of the promulgation of Standards No. 109 and No. 110 was to give a 'blanket' approval of all rims cited within the references. From that time on however, all *new* tire and rim combinations have to be approved by the Bureau. After the tire and rim combination was approved then it was listed within Table I, Appendix A of Standard No. 110.; Standards No. 109 and No. 110 do not have requirements for ri contours. Our Standards only specify the flange letter-code and width for a particular rim designation. Therefore, any request to change a rim dimension of an existing rim does not require a formal action by this Bureau.; Sincerely, Lawrence R. Schneider,Acting Deputy Chief Counsel |
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ID: aiam4212OpenMr. Rohit Vaidya, 10288 9th Street Circle, #103, Miami, FL 33172; Mr. Rohit Vaidya 10288 9th Street Circle #103 Miami FL 33172; Dear Mr. Vaidya: This responds to your April 30, 1986 letter concerning Safety Standar No. 213, *Child Restraint Systems*, and your planned built-in child seat. You asked for information concerning all safety standards that would be applicable to the seat and concerning a pending petition for amending Standard No. 213 to permit the installation of built-in child seats in new motor vehicles. I regret the delay in our response.; Standard No. 213 is the only standard which this agency has issue concerning child restraint systems. It was drafted at a time when add-on or portable systems were the only type of child restraint systems. Accordingly, the requirements of the standard are oriented toward that type of system. However, the agency has granted a petition to broaden the standard to permit the installation of built-in child restraint systems. We expect to issue a proposal regarding this matter later this year. Copies of the standard and the petition are enclosed.; As a new manufacturer of motor vehicle equipment, you should know tha a manufacturer has a variety of responsibilities in addition to certifying compliance with all applicable safety standards. Manufacturers have the responsibility to conduct notification and remedy campaigns for safety-related defects or noncompliances with standards in their products. If a child restraint system fails to comply with Standard No. 213 or contains a safety-related defect, the manufacturer may elect to either (1) repair the child restraint so that the defect or noncompliance is removed, or (2) replace the child restraint with an identical or reasonably equivalent restraint which does not have the defect or noncompliance. Whichever of these options is chosen, the child restraint manufacturer must bear the expense for the remedy.; Installation of your product in a used vehicle would also be affecte by the National Traffic and Motor Vehicle Safety Act. Section 108(a)(2)(A) of the Motor Vehicle Safety Act prohibits any manufacturer, distributor, dealer, or motor vehicle repair business from 'rendering inoperative' in whole or in part, any device or element of design installed in a motor vehicle in compliance with an applicable safety standard. Such a rendering inoperative could occur, for example, if the installer of a built-in child safety seat removed the original vehicle seat, installed a replacement vehicle seat containing the built-in child safety seat, but did not ensure that the seat belt anchorages for adult seating positions in the replacement rear seat continued to meet the location and strength requirements of Standard No. 210, *Seat Belt Assembly Anchorages*. A rendering inoperative could also occur if the installer did not ensure that a replacement vehicle seat continued to meet the strength requirements of Standard No. 207, *Seating Systems*, to minimize the possibility of failure by forces acting on that seat as a result of vehicle impact.; Section 108(a)(2)(A) does not establish any limitations on a individual vehicle owner's ability to alter his or her own vehicle. Under Federal law, individual vehicle owners can themselves install any product they want on their vehicles, regardless of whether that product would render inoperative the compliance of the vehicle's seats or seat belt assembly anchorages with the requirements of Standards Nos. 207 or 210. However, the agency encourages vehicle owners not to install products which could lessen the occupant protection afforded by the original seats or safety belt assembly anchorages and thus adversely affect safety.; For further information concerning these responsibilities, pleas consult the enclosed information sheet for new manufacturers.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1010OpenMr. Harvey M. Klein, Southwest Auto Auction, Inc., 2400 South Central Avenue, Phoenix, AZ 85040; Mr. Harvey M. Klein Southwest Auto Auction Inc. 2400 South Central Avenue Phoenix AZ 85040; Dear Mr. Klein: This is in reply to your letter of February 8, 1973, concerning th Federal Odometer Disclosure Requirements.; Our response to your three questions is as follows: (1) When a title is transferred several times from dealer to dealer each transferor must complete a disclosure form, not just the registered owner.; (2) Where several sales of a vehicle occur before March 1, 1973, and final sale of the same vehicle occurs after that date, only the final sale must have a disclosure form.; (3) If a transferor is not the original owner and does not know tha the indicated mileage is correct, yet does not *know* that the mileage is *incorrect*, he should state the indicated mileage reading without indicating that the mileage is unknown.; Yours truly, Richard B. Dyson, Assistant 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.