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: aiam3923OpenMr. Lynn R. Metzger, President, Mid Bus Inc., P.O. Box 1985, Lima, OH 45802; Mr. Lynn R. Metzger President Mid Bus Inc. P.O. Box 1985 Lima OH 45802; Dear Mr. Metzger: This responds to your February 22, 1985 letter to the National Highwa Traffic Safety Administration (NHTSA) requesting clarification of this agency's definition of a bus. A 'bus' is defined in the definitions section of our motor vehicle safety standards (49 CFR 571.3) as 'a motor vehicle with motive power, except a trailer, designed for carrying more than 10 persons.' You asked whether a vehicle's classification under our regulation is based on the seating capacity of the vehicle as designed, which may vary, or the actual seating capacity of the vehicle as manufactured.; The National Traffic and Motor Vehicle Safety Act require manufacturers to certify that their vehicles as manufactured, comply with our safety standards. Thus, the agency uses the actual seating capacity of the vehicle as manufactured to determine the classification of the vehicle. NHTSA determines the seating capacity of a motor vehicle by identifying the number of designated seating positions in the vehicle. 'Designated seating position' is defined in S571.3 as 'any plan view location capable of accommodating a person at least as large as a 5th percentile adult female, if the overall seat configuration and design and vehicle design is such that the position is likely to be used as a seating position while the vehicle is in motion, except for auxiliary seating accommodations such as temporary or folding jump seats....' Consistent with this definition, we have also counted positions designed to accommodate wheelchairs in determining vehicle seating capacity for the determination of vehicle classification. Under our regulations, a vehicle having a total of more than 10 designated seating positions and wheel chair positions is a bus and a vehicle having a total of 10 or less positions is either a passenger car or a multipurpose passenger vehicle (MPV).; You asked why you are not permitted to build a 6 passenger MPV exactl as you manufacture a school bus. As a MPV, your vehicle must be certified as meeting all of the standards applicable to that vehicle type. You may also voluntarily manufacture the vehicle in compliance with the requirements of our school bus safety standards, as long as the vehicle continues to comply with our standards for MPV's.; A final rule was recently published in the Federal Register (50 F 12029, March 27, 1985) amending Standard No. 206, *Door Locks and Door Retention Components* to exclude doors equipped with wheelchair lifts and audible or visual alarms from the requirements of the Standard. Since you expressed an interest in that amendment, I have enclosed a copy of the final rule for your information.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam2631OpenMr. Takeo Shimoguchi, General Manager, Daido Kogyo Co., Ltd., 1-197 Kumasaka-cho, Kaga, Ishikawa-pref., Japan; Mr. Takeo Shimoguchi General Manager Daido Kogyo Co. Ltd. 1-197 Kumasaka-cho Kaga Ishikawa-pref. Japan; Dear Mr. Shimoguchi: This responds to your April 30, 1977, comments concerning Standard No 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*. Your comments question the advisability of requiring the rim size designation to be stated in the order of diameter by width. This designation would be the reverse of existing Japanese and European practices.; The National Highway Traffic Safety Administration (NHTSA) examine this issue in its response to petitions for reconsideration of Standard No. 120 (42 FR 7140). The agency determined that the rim size designation should be expressed on the label in the manner proposed in the standard (diameter by width) to avoid confusion with the tire size designation which is measured in terms of width by diameter. Since publication of our response to petitions for reconsideration (which included your petition), we have received no information presenting new reasons to alter the chosen format. Therefore, the NHTSA will continue to implement the standard as published in the February 7 Notice.; In a second question, you ask whether the NHTSA requires that th information specified in S5.2 of the standard be listed in any particular order. Although the agency has not specified the order in which the information required in S5.2 should be listed, the NHTSA expects that for purposes of clarity the information in paragraphs (a), (b), and (c) would be grouped together as would the information in paragraphs (d) and (e).; Finally, you note that the symbol 'JIS' must be marked on the rim i accordance with requirements od the Japanese Industrial Standard while NHTSA requires only the letter 'J.' For purposes of uniformity the agency will continue to require the letter 'J' even though this may result in the double marking situation to which you refer.; I trust that this responds fully to your comments. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0381OpenMr. Louis L. Allen, President, Chase Manhattan Capital Corporation, 1 Chase Manhattan Plaza, New York, NY 10005; Mr. Louis L. Allen President Chase Manhattan Capital Corporation 1 Chase Manhattan Plaza New York NY 10005; Dear Mr. Allen: This is in reply to your letter of June 21, 1971 concerning the Tir Identification and Record Keeping regulation (49 CFR Part 574). We are concerned with the points you raise in your letter regarding the confidentiality of tire dealers customer's lists and the extra burden the regulation causes dealers who handle more than one brand of tires.; However, under the National Traffic and Motor Vehicle Safety Act we d not feel we have authority to require the tire manufacturer to choose someone as his designee. Section 113(f) of the Act makes the tire manufacturer responsible for maintaining the records of first purchasers.; As you probably know, any use of the customer's list by the tir manufacturer is expressly prohibited by the regulation. Any violation of this prohibition will be enforced.; I have enclosed for your information a copy of a notice published i the *Federal Register* May 28, 1971 which is relevant to the points you raise.; Thank you for your comments and interest in auto safety. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam5479OpenMr. Earl L. Hartley, Jr. Ryan Freight Services, Inc. 2595 Chandler #10 Las Vegas, Nevada 89120; Mr. Earl L. Hartley Jr. Ryan Freight Services Inc. 2595 Chandler #10 Las Vegas Nevada 89120; Dear Mr. Hartley: This responds to your letter concerning 49 CFR Par 583, Automobile Parts Content Labeling. I apologize for the delay in our response. You stated that you need to provide country of origin information to the auto manufacturers you sell to, and would like confirmation that you are properly interpreting the regulations. We understand that you are an 'outside supplier,' i.e., your company is not owned by an auto manufacturer. (Requirements differ for outside suppliers and allied suppliers.) Your questions, and our responses, are set forth below. Question 1. 583.6(c) We interpret this to mean that if the U.S./Canada value added is 70% or more we are to report the U.S./Canada percentage to be 100%. If the U.S./Canada value added is less than 70% we are to report the U.S./Canada percentage to be -0-% Is this correct? Response. You are partially correct. It is true that, under 583.6(c), equipment supplied by an outside supplier is considered 100 percent U.S./Canadian if 70 percent or more of its value is added in the U.S./Canada, and 0 percent if less than 70 percent is added in the U.S./Canada. However, the specific information which outside suppliers must provide to auto manufacturers is set forth in 583.10. (Outside suppliers of engines and transmissions must also provide the information specified in 583.12. I will assume for the balance of this letter that you are not a supplier of engines or transmissions.) Rather than requiring outside suppliers to report the 100 percent or 0 percent figure, section 583.10 instead specifies that outside suppliers are to provide a statement that the equipment has, or does not have, at least 70 percent of its value added in the United States and Canada. Question 2. 583.7(a), (e), (f) If the U.S./Canadian percentage of the value is -0-% then we should report the two largest 'Major Foreign Sources' which are over 15% each. Is this correct? Response. No. This question suggests a misunderstanding of the differing requirements for auto manufacturers and suppliers. Auto manufacturers are required to calculate, on a carline basis, 'U.S./Canadian parts content' and 'Major sources of foreign parts content.' Suppliers are required to provide specified information about the equipment they supply to enable the auto manufacturers to make these calculations. As indicated above, the information that outside suppliers must provide is set forth in 583.10. Suppliers are not required to provide the two largest 'Major Foreign Sources' of their equipment. Question 3. 583.7(c)(1) This requirement is completely independent from the determination of the percentage of the value determination. Therefore it is possible for a part to be of U.S.A. origin and have -0-% U.S./Canadian percentage of value. Are we correct in this assumption? Response. The answer is yes. It is true that a part could be of U.S./Canada origin under 583.7(c)(1), for purposes of determining major foreign sources of passenger motor vehicle equipment, even though it has less than 70 percent U.S./Canadian content and is hence considered to have 0 percent U.S./Canadian content under 583.6. This reflects the different purposes of 583.6 and 583.7. Section 583.6 sets forth the procedure for determining the U.S/Canadian content of carlines. Under the American Automobile Labeling Act, equipment supplied by an outside supplier is considered 100 percent U.S./Canadian if 70 percent or more of its value is added in the U.S./Canada, and 0 percent if less than 70 percent is added in the U.S./Canada. Section 583.7 specifies the procedure for determining major foreign sources of passenger motor vehicle equipment. The only effect of a determination under 583.7(c)(1) that a part is of U.S./Canadian origin is that it will not be considered to have been contributed by a foreign source. Question 4a. 583.10(a)-(c) From these parts we assume the following requirements: Our certificate must show: 1. The name and address of the supplier, 2. The part number and description of the part or assembly, 3. The selling price to our customer, 4. Whether the part has or does not have 70% of its value from the United States/Canada as determined under 583.6(c), 5. If the United States/Canada percentage is less than 70% the country of origin determined under 583.7(c), 6. For equipment that may be used in an engine or transmission, the country of origin of the equipment, determined under 583.8(c), 7. A certification for the information, pursuant to 583.13 and the date of the certification, and, 8. One certificate can cover multiple parts and assemblies. Response. Your eight stated understandings are correct. With respect to the second, I note that while 583.10(a) does not specifically mention 'part number,' we assume that would be the customary way of identifying unique equipment. Question 4b. If the United States/Canada percentage of the value added is -0- percent, should we show the two largest 'Major Foreign Sources' which are over 15% on our certificate? This information does not seem to be required by 583.10(a). Response. As discussed in our answer to Question 2, suppliers are not required to provide the two largest 'Major Foreign Sources' of their equipment. Question 5. 583.13 This section requires us to certify the information provided on our certificate to be in accordance with DOT regulations. Please provide us with a copy of these DOT regulations or advise where we can secure a copy of these regulations so we can know the regulations to which we are subscribing. Response. The Department of Transportation (DOT) regulations concerning automobile parts content labeling are simply those set forth in 49 CFR Part 583. Question 6. 583.10(c)(1)-(2) We can issue our certificate for the calendar year from January 1 through December 31 of each year. Response. Section 583.10(c)(1) provides that, except as provided in (c)(2), the information provided in the certificate is to be for equipment expected to be supplied during the 12-month period beginning on the first July 1 after receipt of the request from the auto manufacturer or allied supplier. Paragraph (c)(2) provides that the 12-month period specified in (c)(1) 'may be varied in time and length by the manufacturer or allied supplier if it determines that the alteration is not likely to result in less accurate information being provided to consumers. Therefore, your certificate can only be issued for the calendar year if the auto manufacturer or allied supplier to which you supply equipment makes such a determination. I hope this information is helpful. If you have further questions, please feel free to contact Edward Glancy of my staff at this address or by telephone at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel; |
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ID: aiam3954OpenMr. H. Nakaya, Branch Manager, Mazda (North America), Inc., 24402 Sinacola Court, Farmington Hills, MI 48018; Mr. H. Nakaya Branch Manager Mazda (North America) Inc. 24402 Sinacola Court Farmington Hills MI 48018; Dear Mr. Nakaya: Please forgive our delay in responding to your letter of May 30, 1984 asking for interpretations of Standard No. 108 as it applies to center high-mounted stoplamps.; In your letter you stated that the preamble to the final rule discusse the definition of 'window opening' and concluded that the rear window opening shall be the perimeter of the rear glazing that is unobstructed and free of opaqueness. You have presented two rear window designs in which (1) ceramic opaque dots descend in increasing size to the bottom of the glazing and in which (2) shaded material becomes progressively darker as it descends, though the material is translucent, not opaque. You also show a design with an interior-mounted windshield wiper, including motor and cover, placed on the rear vertical centerline above the bottom of the glazing. In each instance you have asked at what point would the National Highway Traffic Safety Administration (NHTSA) consider an 'obstruction' exists for purposes of defining the bottom of the window.; The phrase 'window opening' does not appear in Standard No. 108. Th preamble discussion appears to be irrelevant with respect to the final rule, and was intended as a clarification of proposed location requirements which, in fact, were not adopted. The notice of proposed rulemaking of January 8, 1981, proposed a definition of 'daylight opening' as 'the maximum unobstructed opening through the glazing surface...,' relating to three alternative locations proposed for the lamp in which the term 'daylight opening' was used as a locational reference. For instance, in Alternative 1, proposed paragraph S4.3.1.9(a) would have placed 'the center of the lamp within 3 inches of the outside bottom edge of the rear window daylight opening.' When the final rule was adopted in October 1983, none of the three alternatives was judged acceptable and a requirement allowing more design freedom was adopted omitting all reference to 'daylight opening.' Paragraph S4.3.1.8 simply specified that 'no portion of the lens shall be higher than the top of the back window or lower than three inches below the bottom of the back window. The requirement was even further relaxed in the May 1984 response to petitions for reconsideration in which paragraph S4.3.1.8 was amended to allow mounting 'at any position on the centerline' (note, no limitation on upper mounting height relative to the rear window) and if 'mounted below the rear window, no portion of the lens shall be lower than 6 inches on convertibles, or 3 inches on other passenger cars.' The preamble also clarified that, if the lamp were mounted on the interior, photometric compliance would be judged with the glazing in place.; Thus, whether glazing is opaque or obstructed is not the question manufacturer must ask in determining the location of the lamp with respect to the lower edge of the window. If the lamp is mounted on the interior, it must meet photometric and visibility requirements with the glazing in place, taking into account any graduated dots on or opaqueness of that glazing, and any wiper motor. If the lamp is mounted on the outside, its upper permissible height is determined by the height of the car and not by the window. The question of opaqueness or obstruction is irrelevant to the lower permissible height of 3 inches below the window. The window is the perimeter of its glazing, and 3 inches is measured from the lower edge.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam1969OpenMr. K. Nakajima, Director/General Manager, Toyota Motor Sales, U.S.A., inc., 1099 Wall Street, West Lyndhurst, New Jersey 07071; Mr. K. Nakajima Director/General Manager Toyota Motor Sales U.S.A. inc. 1099 Wall Street West Lyndhurst New Jersey 07071; Dear Mr. Nakajima: This responds to Toyota's June 9, 1975, request for confirmation tha S5.3.2 of Standard No. 105-75, *Hydraulic brake system*, requires a check of the brake system indicator lamp function only when the transmission is in the 'P' (park) position or the 'N' (neutral) position.S5.3.2 specifies:; >>>S5.3.2 All Indicator lamps shall be activated as a check of lam function either when the ignition (start) switch is turned to the 'on' ('run') position when the engine is not running, or when the ignition (start) switch is in a position between 'on' ('run') and 'start' that is designated by the manufacturer as a check position.<<<; The wording of S5.3.2 requires a check of lamp function without regar to the position of the transmission shift lever whenever the ignition switch is in one of the positions described. In the case of vehicles equipped with automatic transmission, this language does not reflect the National highway Traffic Safety Administration's (NHTSA) intent that the check function occur during the process of starting the vehicle.; To incorporate the intended meaning of the requirement into th standard, the NHTSA will shortly issue an interpretative rule that modifies the language of s%.3.2 by limiting the check function to the park an neutral positions for vehicles with automatic transmission.; Sincerely, James D. Schultz, Chief Counsel |
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ID: aiam5183OpenMr. Steve Reeder President & General Manager Trails West Manufacturing P.O. Box 67 Preston, ID 83263; Mr. Steve Reeder President & General Manager Trails West Manufacturing P.O. Box 67 Preston ID 83263; Dear Mr. Reeder: This responds to your letter of April 21, 1993, t Taylor Vinson of this Office, in which you ask questions about the applicability of Federal Motor Vehicle Safety Standard No. 108 to the livestock trailers that you manufacture. The trailer box is 78 inches wide, but the overall vehicle width exceeds 80 inches when the fenders are added. You have asked whether such trailers must be equipped with lamps required of vehicles whose overall width is 80 inches or more (clearance and identification lamps) as they will be installed on the trailer box. In an interpretation published in l976 which remains valid today, the agency stated that 'overall width' refers to 'the nominal design dimension of the widest part of the vehicle . . . exclusive of flexible fender extensions, and mud flaps . . . .' The trailers you manufacture do not appear to be equipped with 'flexible fender extensions', according to the literature that you supplied, and therefore the fenders would be included in determining the overall width. Accordingly, they would be required to be equipped with clearance and identification lamps. Although the clearance lamps will be located on the box, they should be placed, as nearly as possible, to indicate the overall width of the vehicle and as near the top as practicable, as Table II of Standard No. 108 requires. Thus, to answer your second question, side marker lamps would be located as required by Table II rather than Table IV. In determining whether the overall length of the trailer is 30 feet or more for purposes of installation of intermediate side marker lamps and reflectors, you ask whether 'the gooseneck or 5th wheel portion of the trailer which extends over the tow vehicle' should be included. The agency has not adopted a definition of 'overall length.' However, with respect to a trailer that is less than 6 feet in overall length, paragraph S5.1.1.15 requires that 'the trailer tongue' be included in the measurement. Therefore we believe that the calculation of overall length for longer trailers should also include the trailer tongue or equivalent connector to the towing vehicle. You have also asked if 'front clearance lights would be required where the gooseneck or 5th wheel portion of the trailer extends over the tow vehicle.' The answer is yes. Table II of Standard No. 108 requires that amber clearance lamps be located 'on the front' and as near the top as practicable, which we interpret to be the foremost, highest part of the trailer. Your final question relates to regulations for 'safety chains' for your products. We are unaware of any Federal requirements that apply to this item of equipment. States may have adopted specifications such as VESC Regulation V5, or SAE Recommended Practice J697 MAY88, which would apply to vehicles operated within their borders. However, we are unable to advise you on State laws, and suggest that you contact, for an opinion, the American Association of Motor Vehicle Administrators (AAMVA), 4600 Wilson Boulevard, Arlington, Va. 22203. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam2646OpenMr. James R. Green, 3396 Alma Street, Lynwood, CA 90262; Mr. James R. Green 3396 Alma Street Lynwood CA 90262; Dear Mr. Green: In his letter of June 16, 1977, our Mr. Driver, Director of the Offic of Crash Avoidance, commented that although the Federal motor vehicle lighting standard 'is generally in accordance with standards developed and published by the Society of Automotive Engineers, it does not specifically require sealed-beam headlamps.'; This should not be interpreted as an opinion that Federal Motor Vehicl Safety Standard No. 108 does not require sealed beam headlamps. While there is no such requirement *per se* in the text of the standard, Standard No. 108 incorporates by reference SAE Standard J579a *Sealed Beam Headlamp Units for Motor Vehicles*, August 1965, and SAE Standard J580a *Sealed Beam Headlamp*, June 1966. Compliance of headlamps with these standards is required, whether as original or replacement equipment.; |
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ID: aiam5029OpenMr. Mark W. Russo 1480 West Macopin Road West Milford, NJ 07480; Mr. Mark W. Russo 1480 West Macopin Road West Milford NJ 07480; Dear Mr. Russo: This responds to your letter of May 27, 1992, to Mr Charles Gauthier of this agency, which enclosed a copy of R-Bar test data provided by Micho Industries. You requested an 'official `review and comment'' regarding the applicability of Safety Standard 222 to the R-Bar Passenger Restraint System and related issues. The National Highway Traffic Safety Administration (NHTSA) has addressed the use of 'safety bars' in school buses on several occasions in the past. Enclosed for your information are copies of five NHTSA letters which address this subject and which, we believe, will also address your concerns. The letters are addressed to Mr. Michael F. Hecker of Micho Industries, dated May 14, 1992, Mr. Scott K. Hiler of the C. E. White Company, dated January 31, 1991, Honorable Robert J. Lagomarsino, Member of Congress, dated January 8, 1990, and Mr. Joseph F. Mikoll of Transportation Equipment Corporation, dated March 10, 1989 and November 3, 1988. If, after reviewing the enclosed materials, you still have questions concerning this matter, please feel free to contact Mr. Walter Myers of my staff at this address or at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosures; |
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ID: aiam2216OpenMr. Leon C. Huneke, Chemical Engineer, Midland-Ross Corporation, 490 South Chestnut Street, Owosso, Michigan 48867; Mr. Leon C. Huneke Chemical Engineer Midland-Ross Corporation 490 South Chestnut Street Owosso Michigan 48867; Dear Mr. Huneke: #This is in response to your January 30, 1976, lette requesting clarification of my March 7, 1975, letter concerning the relationship between Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses, and Military Specification MIL-H-3992C. #My previous letter indicated that brake hose and brake hose assemblies sold to the military in conformity with MIL-H-3992C are, because of the provisions of 49 CFR 571.7(c), subject to neither the labeling not the performance requirements of Standard No. 106-74 only that equipment which is sold directly to the Armed Forces, the NHTSA interprets this section as also excluding that equipment which is sold to military contractors, under contracts requiring it to conform to military specifications such as MIL-H-3992C, for installation in vehicles which are in turn sold directly to the military. We are considering the issuance of an interpretive amendment of Part 571.7(c) to this effect. #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.