Interpretation ID: nht95-2.28

TYPE: INTERPRETATION-NHTSA

DATE: April 10, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Ralph T. Welch

TITLE: NONE

ATTACHMT: ATTACHED TO 1/5/95 LETTER FROM RALPH T. WELCH TO NHTSA (OCC 10644)

TEXT: Dear Mr. Welch:

This responds to your request for an interpretation whether the Federal Motor Vehicle Safety Standards (FMVSS) specify "the type of odometer" placed in a motor vehicle. As explained below, the FMVSS do not so specify. If an odometer is provided, its mi leage may be stated in kilometers.

Standard No. 101, Controls and displays, specifies requirements for the location, identification, and illumination of motor vehicle controls and displays. Neither Standard No. 101 nor any other FMVSS specifies that an odometer be placed in a motor vehic le or that it register distance in miles, rather than kilometers. However, S5.3.1 (referencing Table 2 "Identification and Illumination of Displays") of Standard No. 101, specifies that if an odometer is provided and the odometer measures mileage in kil ometers, the mileage must be stated as "KILOMETERS" or "km."

I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992.