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: aiam1686OpenMr. Dick Heinrich, Service Manager, Construction Equipment Division, Kyster Company, P. O. Box 289, Kewanee, IL 61443; Mr. Dick Heinrich Service Manager Construction Equipment Division Kyster Company P. O. Box 289 Kewanee IL 61443; Dear Mr. Heinrich: This is in reference to your defect notification campaign (NHTSA No 74-0165) concerning 79 trailers with Standard Forge brake shoes which may be defective.; The letter which you have sent to the purchasers of the subjec vehicles does not contain the precise language which is required by Part 577 (49 CFR), the Defect Notification regulation. Specifically, the second sentence of your letter describes the defect as existing in the brake shoe assemblies. Part 577.4(b) requires, however, that vehicle manufacturers describe the defect as existing in the vehicle itself. The reference in Part 577.4(b) to motor vehicle equipment applies only to equipment campaigns where vehicle (sic) are not involved.; Since in our opinion this discrepancy in your notification letter doe not appear to adversely affect the performance of this campaign, mailing of a revised letter will not be required. A copy of Part 577 is enclosed.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam0994OpenMr. Tatsuo Kato, Nissan Motor Co., Ltd., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Tatsuo Kato Nissan Motor Co. Ltd. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Kato: This is in reply to your letter of January 4, 1973, concerning you continuing uncertainties about the intent of sections S4.3.1.1 and S4.3.1.3 of Standard 210.; In your figure 1, assuming the seat is not adjustable, the contac points would be (b) in the first drawing and (c) in the second. However, a rigid attachment of the length shown in the second drawing would appear to violate the intent of S4.3.1.1 that the angle formed by the webbing in passing from the hardware to the seating reference point should be a forward angle.; In your figure 2, if the bracket can be rotated so that an extension o its centerline would pass through the seating reference point, we would consider point (p) to be the nearest contact point for purposes of S4.3.1.1 and S4.3.1.3.; With respect to the proposed used (sic) of a flexible wire, as shown i figure 3, the ability of the wire to move with reasonable freedom removes it from the category of rigid hardware. We would consider the points shown as (c) and (f) to be the appropriate contact points for purposes of S4.3.1.1 and S4.3.1.3.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4611OpenMr. Bob Sandblom President Bookland 8980 E. Indian Bend Road, Suite Dl Scottsdale, AZ 85256; Mr. Bob Sandblom President Bookland 8980 E. Indian Bend Road Suite Dl Scottsdale AZ 85256; Dear Mr. Sandblom: Thank you for your letter of May l8, l989, addresse to the Department, calling our attention to a dealer practice of placing overlays on the center of highmounted stop lamps. We have received a number of inquiries about this subject, and I enclose a representative response. You are correct that it is not legal for a dealer to create a noncompliance, but you will see from the letter enclosed that the practice is not in and of itself illegal provided that the lamp continues to meet the rather technical requirements of the standard after the overlay is required. We appreciate your interest in motor vehicle safety, and for taking the time to write us. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosure; |
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ID: aiam1413OpenMr. S. A. Spretnjak, Excel Industries, 1003 Industrial Parkway, Elkhart, IN 46514; Mr. S. A. Spretnjak Excel Industries 1003 Industrial Parkway Elkhart IN 46514; Dear Mr. Spretnjak: This is in reply to your letter of January 14, 1974, inquiring whethe Motor Vehicle Safety Standard No. 217, Bus Window Retention and Release' (49 CFR 571,217), prohibits the use of sliding windows as emergency exits in buses. You refer to language in S5.3.1 and S5.4 of the standard which refers specifically to the use of push-out windows as emergency exits.; Standard No. 217 is not intended to prohibit the use of sliding window as bus emergency exits, but such windows must comply with all of the standard's requirements for emergency exits.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3584OpenMr. Bernard S. Horton, 100 Memorial Drive, Cambridge, MA 02142; Mr. Bernard S. Horton 100 Memorial Drive Cambridge MA 02142; Dear Mr. Horton: This responds to your recent letter regarding the roof crus requirements of Federal Motor Vehicle Safety Standard No. 216. You ask why convertibles are excluded from the requirements of the standard, yet the BMW 318 which has a 'targa' roof is not excluded.; Convertibles were excepted from Safety Standard No. 216 when th standard was first issued in 1971 because it was impossible for most convertibles to comply with the requirements. The legislative history of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381, et seq.), which authorizes the issuance of our safety standards, clarifies that Congress did not intend for the safety standards that would be issued to effectively preclude any type of existing motor vehicle. If no exception had been provided, the requirements of Safety Standard No. 216 would have caused the production of convertibles to cease. For this reason alone, they were excepted from the requirements.; The agency has limited the convertible exception to vehicles for whic it is truly impractical to comply. While our regulations do not include a formal definition of 'convertible', the agency has stated that it considers a convertible to be a vehicle whose 'A' pillar or windshield peripheral support is not joined with the 'B' pillar (or rear roof support rearward of the 'B' pillar position) by a fixed rigid structural member. Therefore, passenger cars equipped with a 'sun roof', 'hurst hatch roof' or 'targa roof' do not qualify as convertibles because they have a fixed rigid structural member in the described location. This interpretation applies, moreover, whether the rigid structural member joining the 'A' and 'B' pillars is a hidden reinforcing component or whether the structural member is part of the exterior roof panel.; I am sorry that you are unable to obtain the BMW 318, but this i primarily due to the fact that the manufacturer has chosen not to bring this model into compliance with Safety Standard No. 216. As you probably know, there are other models with 'targa roofs' and 'hurst roofs' that are in compliance with the standard and currently in use.; You also mention the fact that many vehicle custom shops cut one o more panels from vehicles to make them into convertibles or 'targas'. You state that there seems to be no prohibition to this. There are certain prohibitions, however. Section 108(a)(2)(A) of the Vehicle Safety Act specifies that no manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative in whole or part any device or element of design installed on or in a motor vehicle in compliance with a motor vehicle safety standard. This means that custom shops cannot cut panels from a used vehicle's roof if such operation would impair the vehicle's compliance with Safety Standard No. 216. Failure to observe this prohibition could result in civil penalties up to $1,000 for each violation. Please note, however, that custom shops are not precluded by this section from totally removing a vehicle roof, thereby converting the vehicle into a convertible. The prohibition does not apply to such a conversion since the vehicle would not have had to comply with Standard No. 216 if it had originally been manufactured as a convertible.; I realize that these various distinctions may be confusing. If you hav any further questions, please contact Hugh Oates of my staff at 202- 426-2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4241OpenRichard E. Bond, Esq., Assistant General Counsel, Holiday Rambler Corporation, 65528 St. Road 19, Wakarusa, IN 46573; Richard E. Bond Esq. Assistant General Counsel Holiday Rambler Corporation 65528 St. Road 19 Wakarusa IN 46573; Dear Mr. Bond: This responds to your letter asking for an interpretation of 49 CF Part 565, *Vehicle Identification Number--Content Requirements*. I regret the delay in responding to your letter.; The hypothetical situation discussed in your letter refers to corporation which has manufactured vehicle X for several years. The corporation forms a wholly-owned subsidiary to which it transfers the manufacturing operations of vehicle X. You state that the subsidiary corporation will continue to manufacture vehicle X and ask if the Society of Automotive Engineers (SAE) is authorized to transfer the world manufacturer identifier (WMI) code for the corporation to the wholly-owned subsidiary.; In a telephone conversation with Elizabeth Harrison of this office, yo stated that Holiday Rambler is considering transferring the manufacture of commercial cargo trailers to a wholly-owned subsidiary. You also said that the new subsidiary would be responsible for certifying compliance with Federal motor vehicle safety standards and reporting any safety-related defects for these trailers.; Section 4(a) of Part 565 requires the first three characters of vehicle identification number (VIN) to identify uniquely the manufacturer, make and type of motor vehicle if its manufacturer produces 500 or more motor vehicles of its type annually. You indicated that less than 500 commercial cargo trailers are produced each year, therefore, the first three characters of the VIN together with the third, fourth and fifth characters of the fourth section of the VIN must uniquely identify the manufacturer, make and type of motor vehicle. As you know, SAE is authorized by NHTSA to assign manufacturer identifiers.; This agency has not authorized SAE to transfer WMI codes under th circumstances described above. If the WMI code for these trailers, which are now manufactured by Holiday Rambler, were transferred to a new subsidiary, then the WMI would no longer *uniquely* identify the manufacturer. Therefore, your corporation should request the assignment of a new WMI for the subsidiary and not use the WMI assigned to Holiday Rambler for these trailers, if the subsidiary is formed. The new identifier and the information necessary to decipher the characters contained in the VIN must be submitted to this agency under the reporting requirements of section 5 of Part 565.; Please note that the subsidiary must also inform NHTSA under 49 CF Part 566, *Manufacturer Identifier*, of its corporate name and the types of vehicles or vehicle equipment which it will manufacture, and comply with the certification requirements of 49 CFR Part 566, *Certification*.; I hope this information is helpful to you. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1043OpenMr. William J. Bourne, Manager, Transportation Administration, Kraft Foods, 500 Peshtigo Court, Chicago, IL 60690; Mr. William J. Bourne Manager Transportation Administration Kraft Foods 500 Peshtigo Court Chicago IL 60690; Dear Mr. Bourne: This is in response to your letter of February 26, 1973, concerning th Federal Odometer Disclosure Requirements.; With respect to your first question, we confirm your understanding tha a commercial firm trading a vehicle having a gross weight of 16,000 pounds or less is required to give the dealer a disclosure statement.; Your second question concerns the intent of the phrase 'creating security interest,' as used in the definitions of transferee and transferor in section 580.3. The quoted phrase was used to exclude parties to transactions in which liens and similar interests in vehicles are created, but in which the ownership of the vehicle does not change. For example, a bank that lends money for the purchase of a vehicle and that secures its loan by a lien on the vehicle is not a transferee. A dealer who sells a vehicle conveys his ownership and is therefore a transferor, even though he may *also* create a security interest by placing a lien on the vehicle.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5000OpenMr. John Faist DAS Fleet Services Division City of Seattle 8618 2d Avenue, 12th Floor Seattle, WA 98104; Mr. John Faist DAS Fleet Services Division City of Seattle 8618 2d Avenue 12th Floor Seattle WA 98104; "Dear Mr. Faist: This responds to the letter to the National Highwa Traffic Safety Administration (NHTSA) from Chris Kuczynski, Fleet Services Division, City of Seattle Department of Administrative Services, dated February 4, 1992, asking how the provisions of 49 CFR, Parts 554-557, 565-568, 571, 573, 576, 577, and 579 pertained to 'a municipal government agency that transfers, modifies and/or fabricates custom vehicle bodies for use by it's own departments.' In a telephone conversation with Walter Myers of this office on April 3, 1992, you stated that the vehicle modifications referred to in the letter involve only trucks, both light and heavy, that you combine both new and used bodies with both new and used chassis, endeavoring to retain the old engines, power axles, and transmissions to the extent possible, that such modifications include mounting equipment on truck chassis to create such specific-purpose vehicles as dump trucks, cranes, and the like, that some of such modifications and fabrications are done in your own shops while others are contracted out to local body shops, and that passenger cars and buses are not involved. Before addressing the specific issues raised in the letter, some background information may be helpful. The National Traffic and Motor Vehicle Safety Act of 1966, as amended, 15 U. S. Code, 1381 - 1431 (hereinafter 'Safety Act') authorizes this agency to establish Federal motor vehicle safety standards for new motor vehicles and items of motor vehicle equipment. NHTSA, however, does not approve or disapprove motor vehicles or motor vehicle equipment. Rather, the Safety Act establishes a self-certification process which requires each manufacturer, in the exercise of due care, to ensure and certify that its products meet all applicable Federal safety standards. Thereafter, NHTSA will periodically test vehicles and equipment for compliance with the standards and investigate allegations of safety-related defects. Turning now to the modifications to your trucks, we start first with the provisions of 49 CFR, Part 571.7(e), Combining new and used components, which provides in pertinent part: When a new cab is used in the assembly of a truck, the truck will be considered newly manufactured . . . unless the engine, transmission, and drive axle(s) (as a minimum) of the assembled vehicle are not new, and at least two of these components were taken from the same vehicle. NHTSA has consistently interpreted that provision to mean that, by its terms, it applies only to new bodies and not to old ones, and that placing a new body on an old chassis does not produce a new vehicle so long as the engine, transmission, and drive axles, as a minimum, are not new and at least two of which were taken from the same vehicle. Conversely, a new vehicle would result by placing a new body on an old chassis utilizing new, a combination of new and used, or used engine, transmission, and drive axles no two of which were taken from the same vehicle. A new vehicle would also result by placing a body, new or used, on a new chassis. In that case the new chassis is an incomplete vehicle which is defined at 49 CFR, Part 568.3 as: A n assemblage consisting, as a minimum, of frame and chassis structure, power train, steering system, suspension system, and braking system, to the extent that those systems are to be part of the completed vehicle, that requires further manufacturing operations, other than the addition of readily attachable components, such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, to become a completed vehicle. By adding a body to the new chassis, you, the City of Seattle, become a final-stage manufacturer, defined in Part 568.3 as '. . . A person who performs such manufacturing operations on an incomplete vehicle that it becomes a completed vehicle.' As such, you are required by Part 568.6(a) to '. . . C omplete the vehicle in such a manner that it conforms to the standards in effect on the date of manufacture of the incomplete vehicle, . . . .' Part 568.6(b) then requires that 'Each final-stage manufacturer shall affix a label to the completed vehicle in accordance with 567.5 of this chapter.' For your additional information I am enclosing a NHTSA fact sheet entitled INFORMATION FOR NEW MANUFACTURERS OF MOTOR VEHICLES AND MOTOR VEHICLE EQUIPMENT. To summarize, placing a new body on a used chassis does not make a new vehicle if, as a minimum, the engine, transmission, and drive axles are not new and if at least two of those components were taken from the same vehicle. A new chassis, however, is an incomplete vehicle and placing a body thereon, whether new or old, results in a new vehicle which must comply with all applicable Federal motor vehicle safety standards in effect on the date of manufacture of the new chassis, and the final-stage manufacturer who completes the assembly of the vehicle must comply with the certification requirements of 49 CFR, Part 567. Accordingly, in response to your question about the applicability of 49 CFR, Parts 554-557, 565-568, 571, 573, 576, 577, and 579 to your truck customization program, the answer is that if you create a new vehicle, all those provisions apply. If you do not create a new vehicle, none of them do. This is true whatever procedures/steps you choose to utilize in accomplishing your vehicle customization program. One final matter should be discussed before concluding. Section 108(a)(2)(A) of the Safety Act prohibits manufacturers, distributors, dealers, and motor vehicle repair businesses from rendering inoperative any safety device or element of design installed on or in a complying vehicle. That restriction does not apply to private owners, which would include municipalities, who are free to modify their vehicles without regard to whether the vehicles so modified comply with the Federal motor vehicle safety standards. Such restriction would apply, however, to those local body/repair shops to which you contract out some of your customization work. Accordingly, those businesses would have to be very careful to leave intact all the safety devices and features that are on the vehicles that they work on for you. I hope the above information is responsive to your inquiry and will be of assistance to you. If you have any further questions with regard to this matter, please feel free to contact Walter Myers of my staff at this address or by telephone at (202) 366-2992. Sincerely, Enclosure Paul Jackson Rice Chief Counsel"; |
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ID: aiam0202OpenMr. R. O. Sornson, Manager, Highway and Vehicle Safety Relations, Chrysler Corporation, P. O. Box 1919, Detroit, MI 48231; Mr. R. O. Sornson Manager Highway and Vehicle Safety Relations Chrysler Corporation P. O. Box 1919 Detroit MI 48231; Dear Mr. Sornson: Thank you for your letter of January 20, 1970, with which you enclose copies of tables that you have developed for insertion into your consumer information booklets for prospective purchasers. These tables contain the required vehicle descriptions that were missing from your booklets, as I noted in my letter of December 11, 1969.; I am glad that you have decided to alter your existing booklets t conform as closely as possible, under the circumstances, to the regulations. With reference to your discussion of the advantages of various formats, I would simply say that at this time the matter is one of conformity to the regulations, and refer you to the advice in an earlier letter that the vehicle descriptions, in terms in which the vehicles are commonly described to the public, are required to be placed in proximity to the tables. The Bureau is willing to consider these and any other comments you might make as suggestions for further rulemaking to improve the required formats.; I assume that in subsequent printing runs of Chrysler booklets you wil print each vehicle description in close proximity to the pertinent table, so as to bring the booklets into full conformity. The Bureau and its legal staff are prepared to assist you at any time if you have further questions.; Sincerely, Robert Brenner |
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ID: aiam5450OpenMr. C.H. Je Doosan Corporation Pusan Branch 5KA-50 Chungang-dong Chungku, Pusan KOREA; Mr. C.H. Je Doosan Corporation Pusan Branch 5KA-50 Chungang-dong Chungku Pusan KOREA; "Dear Mr. Je: This responds to your letter identifying your company a a 'trading company' and asking for permission from the U.S. Department of Transportation to sell air bags in the United States. As I explain below, no such permission is necessary, but there are some requirements you should be aware of before you begin importing air bags. I am pleased to have this opportunity to explain our laws and regulations to you. The National Highway Traffic Safety Administration (NHTSA) is authorized under Title 49, Chapter 301 of the U.S. Code to issue Federal Motor Vehicle Safety Standards for new motor vehicles and new items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products or conduct pre-sale testing of any commercial products. Instead, Chapter 301 establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. I note that the term 'manufacturer' is defined in 49 U.S.C. 30102(5)(B) as 'a person . . . manufacturing or assembling motor vehicles or motor vehicle equipment or importing motor vehicles or motor vehicle equipment for resale.' (Emphasis added.) NHTSA has exercised its authority under Chapter 301 to establish Standard No. 208, Occupant Crash Protection (49 CFR 571.208). Standard No. 208 requires, among other things, that passenger cars provide automatic crash protection. Also, a phase-in of automatic crash protection requirements for light trucks is in progress. Vehicles equipped with automatic crash protection protect their occupants by means that require no action by vehicle occupants. Compliance with the automatic crash protection requirements of Standard No. 208 is determined in a dynamic crash test. That is, a vehicle must comply with specified injury criteria, as measured on a test dummy, when tested by this agency in a 30 mph barrier crash test. At this time, manufacturers are not required to use a specific method of automatic crash protection to meet the requirements of Standard No. 208. Instead, each automobile manufacturer is allowed to select the particular method for the automatic crash protection installed in its vehicles. 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). However, a recent amendment of Standard No. 208 makes air bags mandatory in all passenger cars and light trucks by the late 1990's. Please note that the automatic crash protection requirement applies to the performance of the vehicle as a whole, instead of setting requirements for the air bag as an individual item of equipment. This approach permits vehicle manufacturers to 'tune' the performance of the air bag to the crash pulse and other specific attributes of each of their vehicle models. However, this approach also means that the Federal standards do not specify specific performance attributes for air bags such as inflated dimensions, actuation time, and the like. It is unclear from your letter if the air bags you wish to import will be sold to manufacturers for installation in new vehicles or if the air bags will be sold as replacement air bags or retrofit air bags for vehicles which do not have air bags as original equipment. If the air bags are sold to manufacturers for installation in new vehicles, the vehicle manufacturer is required to certify that the vehicle complies with all applicable safety standards, including Standard No. 208. If the air bag is added to a previously certified new motor vehicle prior to its first sale, the person who modifies the vehicle would be an alterer of a previously certified motor vehicle and would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the installation of the air bag. (See 49 CFR Part 567.7.) While most of Standard No. 208's requirements are expressed in terms of the performance of the vehicle as a whole and apply only to new vehicles and not to aftermarket equipment, there is one exception to this. Pressure vessels and explosive devices for use in air bag systems must comply with section S9 of Standard No. 208 whether they are part of a new motor vehicle or are aftermarket equipment. Therefore, the manufacturer of these items must certify that they comply with the requirements of S9 of Standard No. 208. Another Federal requirement that would affect the device if it were installed in a used vehicle, either as a replacement or retrofit air bag, is the 'make inoperative' prohibition in U.S. Code Section 30122(b), which provides that: A manufacturer, distributor, dealer, or motor vehicle repair business may not knowingly make inoperative any part of a device or element of design installed on or in a motor vehicle ... in compliance with an applicable Federal motor vehicle safety standard . . . The 'make inoperative' provision would prohibit a commercial business from installing an aftermarket air bag in a manner that would negatively affect the vehicle's compliance with Standard No. 208. You should also note that a replacement or retrofit air bag would be considered 'motor vehicle equipment' within the meaning of the U.S. Code. Therefore, if the air bag contained a defect (either in manufacture, design, or performance) that relates to motor vehicle safety, the manufacturer would be required to conduct a recall campaign to notify owners and to remedy the defect free of charge. You should be aware that recently the manufacturer of an aftermarket air bag that did not provide crash protection benefits to vehicle occupants ceased offering its air bags following a NHTSA investigation. In addition, NHTSA provided information to the Federal Trade Commission concerning the claims made by the manufacturer in its advertising. We suggest you carefully review the manufacturer's test data on the devices you are considering importing to assure yourself that the air bag would afford adequate protection to vehicle occupants in crashes and that the claims made in the company's advertising are true. 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. Please note the regulations concerning manufacturer identification and designation of agent. 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, Philip R. Recht Chief Counsel Enclosure"; |
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Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.