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: aiam1276OpenMr. E.J. Johnson, Administrator, Maryland Department of Transportation, Motor Vehicle Administration, 6601 Ritchie Highway, N.E., Glen Burnie, Maryland 21061; Mr. E.J. Johnson Administrator Maryland Department of Transportation Motor Vehicle Administration 6601 Ritchie Highway N.E. Glen Burnie Maryland 21061; Dear Mr. Johnson: This is in further response to correspondence dated JUly 10, 1973 between the Maryland Department of Transportation and Mr. Bernard Nolan. Mr. Nolan had written to the Maryland State Attorney General's Office regarding the practice of tire dealers of selling tires that have been relabeled 'tube type' by their manufacturer, while representing that it was not necessary, and may even be unsafe, to install tubes in them. You attach a memorandum to you from Mr. Thomas J. Widerman which concludes that the practice does not violate any Federal or State law but recommend that Maryland's proposed tire safety standard be amended to prohibit the practice. You indicate to Mr. Nolan that you are forwarding the matter to this agency for appropriate action.; We believe this practice involves at least a technical violation of th National Traffic and Motor Vehicle Safety Act. Section 108(a) (1) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S1397(a)(1)) prohibits, among other things,the sale of motor vehicle equipment manufactured after the effective date of an applicable safety standard that does not conform to the standard.; We believe a person who sells a 'tube type' tire as a tubeless tire i at least representing that the tire will meet the Federal standard applicable to tires, No. 109, without a tube. Accordingly, we believe that it is appropriate under the Safety Act to test that tire to the standard as a tubeless tire and, if failure occurs, to initiate civil penalty proceeding against the tire seller. That seller may also be liable for civil penalties for certifying the tire as conforming in a false and misleading manner (Sec 108(a) (3) of the Safety Act, 15 U.S.C. S 1397(a) (3)).; I am therefore referring the matter to our enforcement personnel wit the recommendation that they inquire into the matter.; However, I also concur with the recommendation of Mr. Widerman that specific prohibition against this practice be made part of Maryland law. NHTSA's enforcement procedures are civil in nature, and involve determinations that products fail to meet technical tests which are time consuming and costly to run. State criminal procedures would, in our view, be far more effective than NHTSA's procedures in dealing with situations such as this.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4074OpenMr. Takeshi Tanuma, Chief Operating Office, Nissan Research & Development, Inc., 3995 Research Park Drive, P.O. Box 8650, Ann Arbor, MI 48104; Mr. Takeshi Tanuma Chief Operating Office Nissan Research & Development Inc. 3995 Research Park Drive P.O. Box 8650 Ann Arbor MI 48104; Dear Mr. Tanuma: This responds to your letter requesting an interpretation of Part 541 *Federal Motor Vehicle Theft Prevention Standard*. You asked two separate questions which are discussed in detail below.; First, you stated that you plan to introduce a 1987 carline in Marc 1986. This particular carline has been selected as one that will be subject to the requirements of Part 541. However, Part 541 does not become effective until April 24, 1986. You stated your belief that the introduction of the 1987 vehicles in that carline before the effective date of Part 541 means that none of the 1987 vehicles in that carline will be required to comply with Part 541. Your belief is correct.; As you noted, the effective date for Part 541 is April 24, 1986. Thi effective date means that Part 541 applies to all selected carlines beginning with the 1987 model year. However, the legislative history for Title VI of the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 2021 *et seq*.), which Title requires that Part 541 be promulgated, expressly states: 'The theft prevention standard cannot apply to a car in the middle of the model year.' H.R. Rep. No. 1087, 98th Cong., 2d Sess. at 11 (1984).; For purposes of Title VI of the Cost Savings Act, NHTSA believes tha the model year for a carline begins on the day on which a vehicle in that carline is introduced into commerce in the United States. Thus, if a 1987 model year vehicle in a carline is introduced into commerce before the effective date of Part 541, the 1987 model year for that carline would have begun prior to the effective date of the theft prevention standard. Obviously, the requirements of a standard do not apply before the effective date. Given the clear expression of Congressional intent that this theft prevention standard cannot apply to a carline in the middle of its model year, NHTSA concludes that a 1987 model year version of a carline introduced into commerce before the effective date of the theft prevention standard is not subject to the requirements of the theft prevention standard for the 1987 model year. That selected carline would, of course, be subject to Part 541 in the 1988 and subsequent model years.; Second, you stated that Nissan plans to affix a metal plate to th engines and transmissions of carlines selected for coverage under Part 541. You asked whether such a metal plate would appear to comply with the requirements of S541.5(d)(1).; You are correct in assuming that all markings which are affixed to part, whether by means of adhesive, special screws, rivets, or welding, are considered 'labels' and must satisfy the requirements of S541.5(d)(1). However, section 606(c) of the Motor Vehicle Information and Cost Savings Act 915 U.S.C. 2026(c)) requires each *manufacturer* to certify that its vehicles comply with the theft prevention standard. For this reason, NHTSA does not approve or certify that a vehicle or method of marking complies with the theft prevention standard.; If you have any further questions or need more information on thi subject, please contact Steve Kratzke of my staff at this address or by telephone at (202) 426-2992.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1626OpenMr. Harold N. Wirt, Vice President - Operations, Krown Manufacturing Company, Inc., 1165 Reynolds Road, Charlotte, MI 48813; Mr. Harold N. Wirt Vice President - Operations Krown Manufacturing Company Inc. 1165 Reynolds Road Charlotte MI 48813; Dear Mr. Wirt: This is in reference to your letter of October 4, 1974, concerning you recall campaign (NHTSA No. 74-0124) involving improperly machined P.O.L. nipples which were attached to L.P. gas regulators furnished by the Marshall Brass Company for use on camping trailers.; Since your company had not determined that a safety-related defec within the meaning of the National Highway Traffic Safety Act of 1966 (the Act) existed until after receipt of our letter of September 23, 1974, we agree with your reasoning that the first quarterly report should cover the period ending December 31, 1974.; Although your revised owner notification letter is not technicall correct, it appears to be adequate from the owner's point of view. An additional revision and mailing will therefore not be necessary. Specifically, the second sentence of your letter is incorrect in that it states that the National Highway Traffic Safety Administrator has determined the existence of the safety-related defect. Our letter of September 23, 1974, did not constitute a formal determination by the Administrator, but was merely intended to explain your company's legal obligations and to persuade your company to make such a determination. Since you stated in your letter of August 5, 1974, that a potential defect exists, but only expressed your opinion that the Act did not apply, it was felt that a defect determination by your company was likely to occur. A campaign number was therefore assigned for recordkeeping purposes.; The second sentence of your letter should also have described th defect as existing in the vehicle itself, rather than describing the defective part. The reference to 'item of motor vehicle equipment' in Part 577.4(b) refers only to campaigns in which vehicles are not involved.; It is hoped that these comments will assist you if the necessity o conducting another safety defect notification campaign should ever occur in the future.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam0934OpenMr. Arthur B. Chivvis, Executive Director, Urethane Safety Group, The Society of the Plastics Industry, Inc., 250 Park Avenue, New York, NY, 10017; Mr. Arthur B. Chivvis Executive Director Urethane Safety Group The Society of the Plastics Industry Inc. 250 Park Avenue New York NY 10017; Dear Mr. Chivvis: Thank you for your letter of December 6, 1972, to Mr. Douglas Toms regarding terminology used in flammability tests and your concern for usage of positive designations instead of description terms.; We concur in the need to use terminology that can be standardized an universally understood as a means for preventing ambiguities. In view of the many flammability performance qualities that are subject to evaluation by test methods covering a wide range of exposure conditions, it is not surprising that descriptive terminology has found wide range.; We would appreciate receiving any definitions that your group ha adopted for flammability testing to standardize on terminology.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam2909OpenMr. Brian Gill, American Honda Motor Co., Inc., P.O. Box 50, Gardena, California 90247; Mr. Brian Gill American Honda Motor Co. Inc. P.O. Box 50 Gardena California 90247; Dear Mr. Gill: This is in response to your letters of October 9, 1978, and October 20 1978, concerning Federal Motor Vehicle Safety Standard No. 115, *Vehicle identification number*.; Since the agency was considering petition for reconsideration when you letter was received, we concluded that it would be more helpful to respond to your letter after the revised standard was issued. A copy of a notice of the amendments to the standard and a copy of a notice of proposed rulemaking to further amend the standard are enclosed.; The type face shown in the attachment to your letter of October 9 1978, meets the requirements of S4.3.1. Since the standard does not specify a location for the placement of the VIN on motorcycles, it may be stamped on the certification label. However, Honda should also consider stamping the VIN on the cycle frame as well, to aid in recovery if the motorcycle is stolen.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam4424OpenEllen A. Lockwood, Esq. Assistant U.S. Attorney United States Attorney District of Guam Suite 502-A PNB 238 O'Hara Street Agana, Guam 969l0; Ellen A. Lockwood Esq. Assistant U.S. Attorney United States Attorney District of Guam Suite 502-A PNB 238 O'Hara Street Agana Guam 969l0; "Dear Ms. Lockwood: This is in reply to your letter of September 24 l987, to Jim Marquez, the former General Counsel of this Department. You have asked about the applicability to the Commmonwealth of the Northern Marianas (CNMI) of l5 U.S.C. l38l, and l9 C.F.R. l2.80. The National Traffic and Motor Vehicle Safety Act, l5 U.S.C. l38l et seq., as you have noted, applies to the CNMI through Section 502(a)(2) of the 'Covenant to Establish the Commonwealth of the Northern Mariana Islands in Political Union with the United States,' and is a 'State' within the meaning of l5 U.S.C. l39l. This means that it is a violation of l5 U.S.C. l397(a)(1)(A) to import into the CNMI any motor vehicle that does not comply with all applicable Federal motor vehicle safety standards. As authorized by l5 U.S.C. l397(b)(3), the Departments of Transportation and Treasury issued joint regulations to enforce the importation prohibition of l397(a)(l)(A). As the authority of the Customs Service is limited to the Customs Territory of the United States, these regulations apply only to 'States' within this Territory. They do not apply to Guam, American Samoa, the Virgin Islands, and the CNMI, 'States' that lie without the Customs Territory of the United States. It is our understanding that each of these 'States' enforces l397(a)(1)(A) within its borders through an Executive Order issued by the Governor, designating an appropriate local agency for this task. In the Virgin Islands, for example, the Department of Public Safety will not register any vehicle that lacks the label required by 49 C.F.R. Part 567 Certification certifying compliance with all applicable Federal motor vehicle safety standards. I enclose representative copies of correspondence that the National Highway Traffic Safety Administration has had with the Virgin Islands and the CNMI on this subject. Sincerely, Erika Z. Jones Chief Counsel Enclosures"; |
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ID: aiam0467OpenMr. James V. Blethen, 924 47th Avenue, N.E., Minneapolis, Minnesota 55421; Mr. James V. Blethen 924 47th Avenue N.E. Minneapolis Minnesota 55421; Dear Mr. Blethen: In your letter of October 21 to Mrs. Petruska, out docket clerk, yo ask whether your rearview mirror idea is 'legal or permissible.' My answer, of course, is restricted to the permissibility of such a mirror by the Federal motor vehicle safety standards.; Federal Motor Vehicle SAfety Standard No. 111, *Rearview Mirrors*, doe not apply to mirrors *per se* by specified requirements that must be met by rearview mirrors mounted in new passenger cars and multipurpose passenger vehicles. There are no Federal safety requirements directly applicable to mirrors, and thus manufacture and sale of your rearview mirror is not prohibited by the National Traffic and Motor Vehicle SAfety Act of 1966.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4977OpenMr. Lance Watt Director of Engineering The Flxible Corporation 970 Pittsburgh Drive Delaware, Ohio 43105-2859; Mr. Lance Watt Director of Engineering The Flxible Corporation 970 Pittsburgh Drive Delaware Ohio 43105-2859; "Dear Mr. Watt: This responds to your letter of February 11, l992 asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it relates to several scenarios regarding the wiring and use of optional brake retarder transmissions on city transit buses manufactured by your company. In your current design, the retarder is designed so that it is electrically operated during the initial travel of the service brake pedal. As the service brake pedal is further depressed, the service brakes are activated, and this in turn illuminates the stop lamps. You have enclosed a copy of my letter of September 20. 1990, confirming that this design conforms to Standard No. 108, specifically S5.5.4 which states that 'The stop lamps on each vehicle shall be activated upon application of the service brakes.' Since that time, several additional scenarios have presented themselves. First, some customers have requested that the transmission retarder be activated when the accelerator pedal is released, rather than when the brake pedal is applied. In this configuration, the stop lamps would not be illuminated, 'and therefore, following vehicles may be unaware of this sudden reduction in vehicle speed', unless the service brakes were also applied. However, some customers wishing this option would like to have the stop lamps illuminated by the retarder, that is to say, when the accelerator is released. Second, some customers have also requested a retarder cut-off switch in order to disable the retarder during icy or slippery road conditions. In such a case, the stop lamps would also be activated at the time of accelerator release 'with minimal if any change in vehicle forward speed, and again, potentially with no intent on the part of the driver to use the service brakes.' To date, your company has resisted these requests, but these customers, without a specific NHTSA interpretation on the point, threaten to declare your company a nonresponsive bidder on transit bus procurements. You have asked whether a noncompliance with section S5.5.4 would result 'if the stop lamps were activated without depressing the brake pedal as requested by our customers.' The purpose of the retarder feature is to provide supplemental braking to city transit buses. This braking results in the deceleration of the vehicle. A stop lamp is defined by SAE Standard J1398 MAY85 Stop Lamps for Use on Motor Vehicles 2032 mm or More in Overall Width as one that indicates 'the intention of the operator of a vehicle to stop or diminish speed by braking.' Whenever the brake retarder is activated with the intent of diminishing speed by braking, Standard No. 108 does not require that the stop lamps be activated. The only mandate of the standard (S5.5.4) is that when the service brakes are applied, the stop lamps must be illuminated. Nor does Standard No. 108 prohibit illumination of the stop lamps by release of the accelerator pedal followed by activation of the retarder. This is because the intention of the driver is to diminish speed by the braking action of the retarder. We distinguish this situation from the one in an interpretation provided Larry Snowhite, Esq. on January 25, 1990, in which a device activated the stop lamps whenever the accelerator pedal was released, regardless of the intent of the driver. Activation of the stop lamps initiated by release of the accelerator pedal is permissible only when the intent of the driver is to reduce the speed of the vehicle by an immediate subsequent act of braking, whether that is achieved through his use of the service brake system, use of retarders, or a combination of the two. However, a configuration where the stop lamps operate in the absence of service brake application or activation of a retarder system (as appears to occur when a retarder cut off switch has been activated) would be subject to S5.1.3 of the standard. This prohibits the installation of motor vehicle equipment that impairs the effectiveness of the lighting equipment required by Standard No. 108. In this instance, the retarder cut off feature would permit the stop lamps to send the false signal that the operator intended to stop or reduce vehicle speed when, in fact, there was no intent to do so. I hope that this answers your question. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam0037OpenMr. Tsutosu Nomiyama, Managing Director, Japan Automobile Manufacturers Association, Inc., 18, 2-Chome Marunouchi Chiyoda- Ku, Tokyo, Japan; Mr. Tsutosu Nomiyama Managing Director Japan Automobile Manufacturers Association Inc. 18 2-Chome Marunouchi Chiyoda- Ku Tokyo Japan; Dear Mr. Nomiyama: In your letter to me dated November 25, you have raised severa questions relating to the status of Japanese motorcycles manufactured after December 31, 1967, and shipped to the United States without windshields.; Specifically you have asked: >>>'1. Is the . . .understanding [correct] that the importation o motorcycles not equipped with windowshields and/or any glazing material will not violate the . . . National Traffic and Motor Vehicle Safety Act of 1966.'<<<; *Answer*: Your understanding is correct. Motorcycles are not require to be equipped with windshields, and conformity to Initial Federal Motor Vehicle Safety Standard No. 205 is required only if motorcycles are equipped with windshields.; >>>'2. In case motor cycles without glazing material are imported, wha shall motorcycle manufacturers do in respect to certificate requirements according to Paragraph 114 of the Act and the Notice of October 31, 1967.'<<<; *Answer*: No certification is required for motorcycles which ar imported without glazing materials.; >>>'3. If certification is not required for motorcycles not equippe with glazing material, would there be any problem at the time of importation at U.S. Customs offices that may naturally seek safety certification on all motor vehicles covered by the Federal Standards.'<<<; *Answer*: Under the proposed joint regulations promulgated by th Treasury Department (Bureau of Customs) and the Department of Transportation covering importation of motor vehicles manufactured after December 31, 1967, vehicles not bearing certification will be admitted upon a declaration by the importer or consignee that such vehicle was manufactured on a date when no standards applicable to the vehicle were in effect. To insure that there is no difficulty at the port of entry, it is contemplated that Customs officials will be notified that motorcycles without windshields may be admitted without certification. The proposed joint regulations were published in the *Federal Register* for November 30, 1967, and I enclose a copy for your consideration.; You have further asked: 'Would there be any particular procedures tha could be taken by Japanese motorcycle manufacturers in advance to avoid such a possibility.'; *Answer*: If the motorcycles are shipped in a manner in which they ar not readily visible, it might be advisable to stencil the shipping containers with a legend to the effect that the motor vehicle therein is not subject to the Federal motor vehicle safety standards (i.e., a motorcycle not equipped with a windshield). Of course, any glazing material shipped for subsequent installation on a motorcycle must bear appropriate certification.; I hope this sufficiently answers your questions. Sincerely, William Haddon, Jr., M. D., Director |
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ID: aiam5235OpenMr. William C. Longo Chief Executive Officer Ram Off Road Accessories P.O. Box 63915 Los Angeles, CA 90063; Mr. William C. Longo Chief Executive Officer Ram Off Road Accessories P.O. Box 63915 Los Angeles CA 90063; "Dear Mr. Longo: This responds to your letter concerning possibl liability involved with marketing a product you manufacture, particularly with respect to installation of the product on vehicles equipped with Supplemental Restraint Systems (SRS), also known as air bags. I regret the delay in responding to your letter. In a June 16, 1993 phone conversation with Mary Versailles of my staff, Troy Wood explained that the products are aftermarket decorative sheet metal accessories that attached to the exterior of vehicles. Your company also makes replacement bumpers for vehicles. As Ms. Versailles explained on the phone, this letter will discuss Federal laws which might be affected by the addition of your products on vehicles equipped with air bags. Potential liability questions should be addressed to a private attorney who is familiar with tort law. By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., Safety Act) to issue Federal motor vehicle safety standards that apply to the manufacture and sale of new motor vehicles and new items of motor vehicle equipment. Section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) prohibits any person from manufacturing, introducing into commerce, selling, or importing any new motor vehicle or item of motor vehicle equipment unless the vehicle or equipment item is in conformity with all applicable safety standards. NHTSA does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. NHTSA has exercised its authority to establish Standard No. 208, Occupant Crash Protection (49 CFR 571.208). Among other things, Standard No. 208 requires that cars be equipped with automatic crash protection. 'Automatic crash protection' means that a vehicle is equipped with occupant restraints that require no action by vehicle occupants. The performance of automatic crash protection is dynamically tested, that is, the automatic systems are required to comply with certain injury reduction criteria as measured by test dummies in a barrier crash test at speeds up to 30 mph. The two types of automatic crash protection currently offered on new passenger cars are automatic safety belts (which help to assure belt use) and air bags (which supplement safety belts and offer some protection even when safety belts are not used). A new Federal statutory requirement will make air bags mandatory in all cars and light trucks by the late 1990's. Standard No. 208 applies to new vehicles, therefore, if your products are installed before the vehicle's first purchase for purposes other than resale, the vehicle would have to be certified as complying with all applicable standards, including Standard No. 208, with your product installed. However, as explained in the phone conversation with Ms. Versailles of my staff, we understand your products are intended as items of after-market equipment. After a vehicle's first purchase for purposes other than resale, i.e., the first retail sale of the vehicle, a provision in Federal law that affects a vehicle's continuing compliance with an applicable safety standard is set forth in section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)). That section 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 ... in compliance with an applicable Federal motor vehicle safety standard. Any violation of this 'render inoperative' prohibition would subject the violator to a potential civil penalty of up to $1,000 for each violation. The 'render inoperative' provision would prohibit a commercial business from installing your product on a vehicle equipped with an air bag in a manner that would negatively affect the vehicle's compliance with Standard No. 208 or any other safety standard. For example, the installer would have to be careful not to activate a sensor while attaching your product, causing the air bag to deploy. Please note that the 'render inoperative' prohibition would apply to a manufacturer, distributor, dealer, or repair business installing your product, and not to your company as the manufacturer of the product. Also note that the 'render inoperative' prohibition does not apply to modifications vehicle owners make to their own vehicles. Thus, Federal law would not apply in situations where individual vehicle owners install your product on their own vehicles, even if the installation were to result in the vehicle no longer complying with the safety standards. However, individual States have the authority to regulate modifications that individual vehicle owners may make to their own vehicles. I have enclosed an information sheet that identifies relevant Federal statutes and NHTSA standards and regulations affecting motor vehicle and motor vehicle equipment manufacturers, and explains how to obtain copies of these materials. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure"; |
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.