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: aiam4656OpenRobert N. Levin, Esq. Hudock & Levin 1101 Connecticut Avenue, NW Suite 910 Washington, DC 20036; Robert N. Levin Esq. Hudock & Levin 1101 Connecticut Avenue NW Suite 910 Washington DC 20036; "Dear Mr. Levin: This responds to your letter on behalf of one of you clients, seeking information on how our law and agency regulations might affect the installation of sun roofs in vehicles. You stated that your client is an automobile repair facility. According to your letter, you recently discovered this agency's regulation (49 CFR /567.7) requiring vehicle alterers to affix to the vehicles they alter a label certifying that the vehicle as altered continues to comply with all applicable safety standards. You asked whether such certification labels must be affixed by your client to those vehicles on which it installs a sun roof. I am pleased to have this opportunity to explain the requirements of our laws and regulations for you. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) authorizes this agency to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Two of those safety standards could be relevant to a repair shop's installation of sun roofs on motor vehicles. Standard No. 205, Glazing Materials, (49 CFR /571.205) sets performance requirements for glazing materials installed in new motor vehicles and for new glazing materials for use in motor vehicles. Any glazing incorporated in a vehicle's sun roof would have to conform to the applicable performance requirements set forth in Standard No. 205. In addition, installation of a sun roof could affect a vehicle's compliance with Standard No. 216, Roof Crush Resistance - Passenger Cars, (49 CFR 571.216), which sets forth strength requirements for roofs of passenger cars. Section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) specifies that, 'No person shall manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States, any motor vehicle or item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect under this title unless it is in conformity with such standard ...' Because of this statutory requirement, any person or business that installs sun roofs in new motor vehicles must certify that the vehicle continues to comply with the requirements of all applicable safety standards, including Standards No. 205 and 216. The form and contents for this certification are set forth in 49 CFR Part 567, Certification. Any manufacturer that installs a sun roof on a new motor vehicle is required by /567.4 or /567.5 to certify that the vehicle conforms to the requirements of all applicable safety standards. Any person or business that adds a sun roof to a previously certified new motor vehicle prior to its first sale for purposes other than resale would be required to certify the vehicle's continuing compliance with all applicable safety standards, in accordance with /567.7. Such a person or entity is an 'alterer' for the purposes of Part 567. (Persons or entities that modify vehicles by using a 'readily attachable component' or performing a 'minor finishing operation' are not considered 'alterers.' Modifications involving a readily attachable component or a minor finishing operation are instead subject to the requirements of 49 CFR /567.6. However, NHTSA does not consider a sun roof to be a 'readily attachable component' nor is the installation of a sun roof a 'minor finishing operation.' Hence, this exception is not relevant to your client's activities.). In addition to these certification requirements, an 'alterer' is considered a 'manufacturer' for the purposes of the Safety Act. Among other things, this means an alterer is responsible for notification and remedy of defects related to motor vehicle safety and noncompliances with applicable Federal motor vehicle safety standards arising from the alterations, as specified in sections 151-160 of the Safety Act (15 U.S.C 1411-1420). I have enclosed a general information sheet for new manufacturers that generally describes our statutory and regulatory requirements, and explains how to obtain copies of those statutes and regulations. The certification and labeling requirements set forth in section 114 of the Safety Act (15 U.S.C. 1403) and in Part 567 apply to vehicles only until the first sale of the vehicle for purposes other than resale. Thus, once a vehicle has been purchased by a consumer, persons that modify that vehicle for its owner (e.g., by installing a sun roof) are not required to certify or label the vehicle by this agency's statutes or regulations. A different statutory provision applies to modifications made by a repair shop to vehicles after the first purchase. Section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)) provides that, 'No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in 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, ...' To comply with the obligations imposed by this 'render inoperative' provision, your client should examine the sun roofs it installs and the means of installation for those sun roofs, and compare those with the requirements of Standards No. 205 and 216. After such an examination and comparison, your client should be able to decide if the sun roof installations it performs result in any apparent violations of the 'render inoperative' provision of the Safety Act. If your client decides there is no apparent 'render inoperative' violation, Federal law does not require any additional actions, such as labeling or certification, on your client's part in connection with the installation of sun roofs in vehicles after the first purchase of those vehicles. You should be aware that NHTSA may reexamine your client's decision and make its own determination of whether your client's sun roof installations may have violated the 'render inoperative' provision in the Safety Act in the context of an enforcement proceeding. I hope this information is helpful. If you have any additional questions, please feel free to contact Mr. Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosures"; |
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ID: aiam3193OpenMr. Richard Tearle, Product Planing (sic) and Development, Volvo of America Corporation, Rockleigh, NJ 07647; Mr. Richard Tearle Product Planing (sic) and Development Volvo of America Corporation Rockleigh NJ 07647; Dear Mr. Tearle: This is in response to your recent letter and visit to the NHTS regarding the proper designated seating capacity for the Volvo 262C Coupe. The rear bench seat in this vehicle is 53.15 inches wide and has two depressed areas with contoured upholstery to fashion bucket seats. You ask whether the seat may be designated as having only two seating positions.; It is the agency's opinion that the rear seat in the Volvo 262C Coup must have three designated seating positions. The definition of 'designated seating position' provides, in part, that any bench or split-bench seat having greater than 50 inches of hip room shall have not less than three designated seating positions, 'unless the seat design or vehicle design is such that the center position cannot be used for seating' (49 CFR 571.3). The rear seat in the Volvo Coupe is substantially over this 50-inch caveat in the definition, since it has more than 53 inches of hip room. Further, the seat design is not such that the center position cannot be used for seating. The center position is well padded on both the seat cushion and the seat back and there is no impediment to use of the position. This was demonstrated when several persons sat at the center position when your demonstration vehicle was brought to the agency.; Your letter mentions that the Volvo Coupe has less head room than othe Volvo models, yet there is sufficient head room even at the center position for large persons to occupy the seat. Therefore, we do not believe that the vehicle design is such that the center position cannot be used. The fact that the two outboard positions of the rear seat are aesthetically designed to appear as bucket seats is irrelevant, since the center position is a well-padded integral part of the entire bench seat. Other current models have the same type bucket seat appearance in the rear seat, yet because of hip room have three designated seating positions. You might examine the 1978 Oldsmobile Regency Sedan, for example.; We noted in the demonstration model that the rear seat of the Volv Coupe has an arm rest at the center position that folds into the seat back. If the design of this arm rest were modified to be permanently attached to the seat cushion, the center position could not be used., The bench seat would then qualify as a two-person seat under the definition of 'designated seating position'.; Finally, I would emphasize that this letter only represents th agency's opinion based on the information supplied in your letter and an examination of the demonstration model brought to the agency. The NHTSA does not pass approval on any vehicle design, for any safety standards, prior to the actual events that underlie certification. It is up to the manufacturer to determine whether its vehicles comply with all applicable safety standards and regulations, and to certify the vehicles in accordance with that determination.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1004OpenMr. Raymond Fink, The Gates Rubber Company, 999 South Broadway, Denver, Colorado 80217; Mr. Raymond Fink The Gates Rubber Company 999 South Broadway Denver Colorado 80217; Dear Mr. Fink: This is in reply to your letter of January 24, 1973 inquiring what NHTSA would consider to be an appropriate generic name for Dupont's Fiber B. #The approval of generic names of cord materials is under the jurisdiction of the Federal Trade Commission. We understand that agency has issued a temporary approval with regard to this material, and that a further petition is currently under review. For purposes of conformity to Standard No. 109 we will, of course, accept any generic name approved by the Federal Trade Commission. #If you desire further information regarding this matter, you may write to Mr. Edward B. Finch, Assistant Director for Textiles and Furs, Federal Trade Commission, Washington, D.C. 20580. #Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
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ID: aiam3039OpenMr. Maurice H. Allmacher, Project Engineer, Vehicle Regulations, Volkswagen of America, Inc., 7111 East Eleven Mile Road, Warren, MI 48090; Mr. Maurice H. Allmacher Project Engineer Vehicle Regulations Volkswagen of America Inc. 7111 East Eleven Mile Road Warren MI 48090; Dear Mr. Allmacher: This is in response to your letter of June 1, 1979, regarding th provision of Uniform Tire Quality Grading (UTQG) information to vehicle first purchasers (49 CFR 575.104(d)(1)(iii)). You ask whether UTQG information must be provided to first purchasers of vehicles manufactured after the UTQG sidewall molding effective date for the type of tire used on the vehicle, if the vehicle is equipped with tires manufactured prior to the effective date.; Section 575.104(d)(1)(iii) requires that tire grading information b furnished, in the case of bias- ply tires,; >>>'...to the first purchaser of a new motor vehicle, other than motor vehicle equipped with bias-ply tires manufactured prior to October 1, 1979, ...'<<<; Thus, UTQG first purchaser information is not required for vehicle manufactured after the bias-ply sidewall molding effective date of October 1, 1979, but equipped with tires manufactured prior to that date. The regulation applies in the same manner to vehicles equipped with bias-belted and radial tires manufactured prior to April 1, 1980, and October 1, 1980, respectively.; In order to avoid confusion regarding the date of manufacture of tire installed on particular vehicles, manufacturers may choose to supply UTQG information to all first purchasers of vehicles manufactured after the effective date for sidewall molding for the tire type used as standard equipment on the vehicles.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4206OpenHerbert C. Glesmann, President, REMCO, 4138 So. 89th Street, Omaha, NE 68127; Herbert C. Glesmann President REMCO 4138 So. 89th Street Omaha NE 68127; Dear Mr. Glesmann: This is in response to your letter of June 4, 1986, and your subsequen conversation with Judith Kaleta of the Office of Chief Counsel and Richard Morse, Chief of the Odometer Fraud Staff.; Your company, REMCO, has designed a system whereby the odometer on vehicle being towed behind a recreational vehicle (RV) would not accumulate mileage. As you describe it, it is a mechanical disconnect system. Disconnection can only be from the RV by use of a mechanical clutch system while the towed vehicle is connected to the RV. When the towed vehicle is disconnected from the RV, the odometer functions automatically.; The Federal law states that 'No person shall, with intent to defraud operate a motor vehicle on any street or highway knowing that the odometer of such vehicle is disconnected or nonfunctional.' 15 U.S.C. S 1988. Therefore, you asked whether in NHTSA's opinion, the use of the system violates the law.; While the term 'operate' has not been defined in Title IV of the Moto Vehicle Information and Cost Savings Act (the 'Act'), 15 U.S.C. SS 1981-1991, NHTSA has interpreted it to mean drive or tow with a load on the major components. When a vehicle is driven, load is put on the engine, transmission and other components of the drive train. Because REMCO's system puts no load on any components of the drive train, the towed vehicle is not being operated on the streets or highways in violation of the Act. However, persons utilizing the system should be advised that they must notify their buyer of the fact that the vehicle's odometer was disconnected.; Federal regulations, 49 C.F.R. S 580.4, provide for the inclusion o two sets of certifications on the odometer disclosure statements which must be completed at the time a vehicle is transferred. Transferors who tow their vehicles utilizing your system should check the first box of the first set which reads:; >>>I hereby certify that to the best of my knowledge the odomete reading as stated above reflects the actual mileage of the vehicle described below.<<<; However, there is no statement in the second set of certification which applies to this situation. Therefore, transferors who have used your system to tow their vehicle should add a fourth statement which reads:; >>>I hereby certify that the odometer was disconnected when the vehicl was in tow.<<<; The purpose of the Act is to establish certain safeguards for th protection of motor vehicle purchasers. We feel this disclosure is consistent with the purpose of the Act.; I hope this information is helpful to you. If you have any additiona questions, do not hesitate to call me.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4713OpenMr. Bill Waltz Wagner Division Cooper Industries, Inc. 155 Algonquin Parkway Whippany, NJ 07981; Mr. Bill Waltz Wagner Division Cooper Industries Inc. 155 Algonquin Parkway Whippany NJ 07981; Dear Mr. Waltz: This is in reply to your letter requesting permissio for deviations from marking requirements for round sealed beam headlamps. Wagner has been asked to assemble some headlamps designed to appear as closely as possible to those produced by Guide Lamp in the l950's. The lamps would be marked 'l' and '2' in accordance with the nomenclature of the day, rather than '2Dl', '1C1', and '2C1', as required by Standard No. 108. The DOT symbol would not be provided, 'since this obviously was not on the original lamps.' You have informed us that the lamps 'will be made to today's photometric standards' and 'subjected to all the tests currently required of the round headlights.' Finally, 'they will be distributed on a limited basis through antique parts dealers.' I am sorry, but we have no authority to exempt manufacturers of motor vehicle equipment from any requirements of the Federal motor vehicle safety standards. Our temporary exemption authority under l5 U.S.C. 1410 extends only to motor vehicles. Further, we have no authority to exempt manufacturers of either vehicles or equipment from their statutory obligation to certify through use of the DOT symbol that their products meet all applicable Federal motor vehicle safety standards. Under Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment, the motor vehicle lamps which you have identified, and for which you ask an exemption are designated Type C and Type D sealed beam headlamps. As such, they must be designed to conform to the photometric requirements of SAE Standard J579c, December l978, which are incorporated by reference in Standard No. 108. They are considered replacement equipment, and must conform to all requirements of Standard No. 108, including marking and certification. Standard No. 108 covers both original and replacement vehicle equipment. Depending on the vehicle category, it became effective for original equipment on January 1, l968, and January 1, l969. On January 1, l972, it became effective for equipment intended to replace original equipment on all motor vehicles manufactured on and after January 1, l972. Therefore, it might appear that the standard would not apply in any event to replacement equipment for l950's vehicles. However, the headlamps you describe are designed to conform to all contemporary requirements, except marking and certification. Even though intended for use on l950's vehicles, these circular headlamps are interchangeable with circular headlamps installed on any vehicle manufactured after the effective dates of Standard No. 108. Therefore, they must be designed to conform with Standard No. 108, and marked and certified accordingly. The intended markings 'l' and '2' would signify mistakenly that the headlamps were designed to conform to SAE Standard J579a, October l965 (which also did not require the DOT symbol on the lens). Until June l989, SAE J579a was incorporated in Standard No. 108 as a permissible option to SAE J579c, but the agency deleted it as the lamps appeared to be out of production. However, even had J579a been retained, we could not have allowed the lenses of headlamps manufactured to J579c to be marked according to J579a. Sincerely, Stephen P. Wood Acting Chief Counsel /; |
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ID: aiam1511OpenMr. Ronald J. Hansing, Project Engineer, The Adams & Westlake Company, 1025 North Michigan Street, Elkhart, IN 46514; Mr. Ronald J. Hansing Project Engineer The Adams & Westlake Company 1025 North Michigan Street Elkhart IN 46514; Dear Mr. Hansing: This is in reply to your letter of April 16, 1974, concerning a interpretation of the requirements of Motor Vehicle Safety Standard No. 217, Bus Window Retention and Release' (49 CFR 571.217). You appear to ask whether bus windows containing tempered glass must meet the release requirements of paragraph S5.3.2 after (as well as before) the retention test required by S5.1 when the glass breaks during the retention test. You state that tempered glass, once broken, is easily removed from the entire lite by touch, implying that when this is the case there is no longer a need for any release mechanism to be further tested.; Paragraph S5.3.2 requires the release mechanism to meet specifie requirements both before and after the window retention test of S5.1 irrespective of the glazing material used in the lite. Consequently, release mechanisms for windows of tempered glass must conform to the requirements even though the glass may be broken during the retention test.; While your argument that the requirement seems unnecessary whe tempered glass is used is not without some basis, it is also quite likely, in our view, that bus passengers in a crash may be ignorant of the quality of tempered glass to which you refer and thus still attempt to operate the emergency exit using its release mechanism.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3486OpenMs. Shirley C. Jennings, President, DeJen Products Co., 26 Belridge Road, New Britain, CT 06053; Ms. Shirley C. Jennings President DeJen Products Co. 26 Belridge Road New Britain CT 06053; Dear Ms. Jennings: This responds to your recent letter to Administrator Peck regarding warning device you have developed called 'Call Safe.' This product is a reflective letter 'H' which is designed to be placed inside the rear window or windshield of a motor vehicle to call for help. You ask the agency to advertise the avialability of your device in its newsletter.; Federal Motor Vehicle Safety Standard No. 125 (49 CFR 571.125 establishes requirements for emergency warning devices. The standard requires waring devices to be of a uniform construction. Emergency warning devices, for purposes of this standard, are devices which alert drivers to the presence of a disabled vehicle. We assume your device is designed to signal for help concerning *any* emergency in the vehicle, and not just to warn approaching drivers of a disabled car. For example, 'Call Safe' could be used by a driver who has suddenly become ill and needs help. If this is true, the agency would conclude that Standard No. 125 does not apply to the 'Call Safe' device and you, therefore, would not be prohibited by the standard from offering this device for sale as motor vehicle equipment.; Regarding your request, the National Highway Traffic Safet Administration does not endorse specific products. Please contact this office if you need further assistance.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4343OpenMr. John B. White, Engineering Manager, Product Engineering, Michelin Americas Research & Development Corp., P. O. Box 1987, Greenville, SC 29602; Mr. John B. White Engineering Manager Product Engineering Michelin Americas Research & Development Corp. P. O. Box 1987 Greenville SC 29602; Dear Mr. White: This responds to your letter seeking an interpretation of Standard No 119, *New Pneumatic Tires for Vehicles Other Than Passenger Cars (49 CFR S571.119). Specifically, you stated that you currently mark a tire with the size designation 385/65 R 22.5 Load Range J. You also stated that this tire has the same dimensions as a 15 R 22.5 Load Range J tire. You asked whether Standard No. 119 would prohibit the following size designation from being marked on the tire:; >>>385/65R22.5 LRJ<<< >>>(15R22.5)<<< The marking requirements for tires subject to Standard No. 119 are se forth in section S6.5 of the standard. Section S6.5(c) requires that each tire be marked on both sidewalls with 'the tire size designation as listed in the documents and publications designated S5.1.' Section S5.1 of Standard No. 119 requires each tire manufacturer to ensure that a listing of the rims that may be used with each tire the manufacturer produces is available to the public. This may be done either by the individual manufacturer furnishing a document to each of its dealers, to this agency, and to any person upon request, or the manufacturer may rely on the tire and rim matching information published by certain standardization organizations.; With respect to the 385/65 R 22.5 Load Range J tire size, Michelin ha not furnished any individual information for this tire size to the agency. The only standardization organization that has published tires and rim matching information for this tire size is the European Tyre and Rim Technical Organization (ETRTO), which did so in its 1987 yearbook. Accordingly, section S5.2 of Standard No. 119 provides that the information for this tire size in the 1987 ETRTO yearbook is considered to be information for Michelin's tires of that size.; The 1987 ETRTO yearbook shows the tire size only as 385/65 R 22.5. A noted above, section S6.5.(c) requires that the tire size designation on the sidewall be 'as listed in the documents and publications designated in S5.1'. Reading this requirement as narrowly as possible, S6.5(c) prohibits Michelin from marking the tires as both 385/65 R 22.5 and 15 R 22.5, since the size is shown only as 385/65 R 22.5 in the publication designated in S5.1 of Standard No. 119.; In a broader sense, the practice of labeling two tire sizes on on tire, as you requested in your letter, was once a fairly common practice and was referred to as 'dual-size markings.' Dual-size markings were a marketing effort by tire manufacturers to try to persuade consumers to change the size and/or type of tire on their vehicles, by representing that this particular tire size was an appropriate replacement for two different sizes of tires. However, the practice of using dual-size markings confused many consumers about the size of the tire on their vehicle. The only purpose of the Federally required markings on tires is to provide consumers, in a straightforward manner, with technical information necessary for the safe use and operation of the tire. The agency concluded that it was inappropriate to permit a marketing technique that was confusing many consumers to defeat the purpose of the required markings on tires. Accordingly, dual-size markings were expressly prohibited for passenger car tires subject to standard No. 109, 36 FR 1195, January 26, 1971.; While Standard No. 119 does not expressly prohibit dual- size markings section S6.5(c) uses the singular when it refers to the 'tire size designation' to be labeled on the tire. Considering the past history associated with dual-size markings, this agency interprets section S6.5(c) of Standard No. 119 as prohibiting a manufacturer from marking a tire with two different size designations, *even if* a document or publication designated in S5.1 were to show two different size designations for the same tire size.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1141OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, OH 45222; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Association 602 Main Street Cincinnati OH 45222; Dear Mr. Pieratt: In your letter of May 14, 1973, you present the fact situation of a equipment manufacturer who installs lighting equipment on a component which he supplies to distributors or dealers, for installation by them on motor vehicles. For purposes of this letter, I assume that the installation occurs before the first sale of the vehicles for purposes other than resale. You ask what the equipment manufacturer should do to advise the distributor or dealer 'that the lamps and/or reflectors which he has affixed to his product meets the published S.A.E. specs required by Standard 108.'; There is no Federal requirement that an equipment manufacturer in thi fact situation supply compliance information, although covered equipment that he sells must continue to conform. The requirements for certifying or otherwise providing information concerning conformity with Standard No. 108 apply to the manufacturer of the lighting equipment, and the manufacturer(s) (final-stage and others) of the vehicle in question. It may well be that the customers of the supplier you describe will demand assurances of conformity through commercial channels.; Yours truly, 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.