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: aiam4901OpenDavid R. Stepp, Esq. Stein Shostak Shostak & O'Hara, P.C. Suite 807 1620 L Street, N.W. Washington, D.C. 20036-5605; David R. Stepp Esq. Stein Shostak Shostak & O'Hara P.C. Suite 807 1620 L Street N.W. Washington D.C. 20036-5605; "Re: Escargot Motorcars, Inc. Reimportation of Volkswagens Dear Mr Stepp: This responds to your letter of July 1, l99l, on behalf of your client, Escargot Motorcars of Canada, with respect to its plan to export Volkswagen Beetles to Mexico for refurbishment, with subsequent reentry into the United States. You have asked for an interpretation that such vehicles may be allowed reentry without further certification. As you have explained it, Escargot Motorcars plans to purchase Beetles that were initially imported into the United States by Volkswagen of America, and certified as complying with all applicable Federal motor vehicle safety standards. After shipment to Mexico, each automobile will be completely stripped of all damaged original parts and the frames will be restored and repainted. The engine will be replaced with a VW engine. The body, sheet metal, interior, bumpers, and lights will be restored or replaced with replacement parts 'and will be exactly as those original to the Volkswagen Beetles for their respective years of manufacture.' Some of the old Beetles will retain their manufacturer's original certification of compliance located on the door post, while others, if the bodies are worn or damaged, 'the entire bodies may be replaced and/or painted and this manufacturer's certification may be damaged or removed.' If the bodies are extensively damaged, Escargot may ship only the chassis to Mexico. You state that '(w)here the manufacturer's certification on the doorpost is preserved after restoration in Mexico, the vehicles clearly should be allowed to enter the United States without further certification.' You also state that further certification is also unnecessary for vehicles no longer bearing the certification label, or whose door post condition is such that it must be removed during restoration, because that vehicle's VIN will indicate that it was originally imported into the United States as a certified and complying car. Similarly, those vehicles which are stripped of their bodies prior to shipment should be allowed entry without further certification 'since the chassis will be preserved and registered.' The appropriate statute is the National Traffic and Motor Vehicle Safety Act (the Act, l5 U.S.C. 1381 et seq.), which provides the authority for the Federal motor vehicle safety standards (49 CFR Part 571), and the vehicle importation regulation (49 CFR Part 591). You suggest that the refurbished Beetles may be admitted without further certification since they were originally manufactured to conform to the Federal safety standards. Thus, it appears that Escargot would seek entry under section 591.5(b), the declaration that the vehicle conforms to all applicable Federal motor vehicle safety standards 'and bears a certification label or tag to that effect permanently attached by the original manufacturer of the vehicle.' The first issue raised by the factual situation described in your letter is whether the 'refurbished' vehicles would be considered to be new or 'used' vehicles. If the refurbishing involves sufficient manufacturing operations for the vehicles to be considered to be new, the vehicles would be required to meet all applicable safety standards in effect at the time of the new manufacturing operations (refurbishing), including the requirements for automatic restraints. However, if the refurbishing involves more minor operations, the vehicles would be considered to be used. As discussed below, only if the vehicles would be considered to be used could they be reimported into the United States based on the original manufacturer's certification label. The range of potential manufacturing operations described by your letter is so broad as to include ones where a vehicle would be considered to be used and ones where a vehicle would be considered to be new. As indicated above, you state the following: After shipment to Mexico, each automobile will be completely stripped of all damaged original parts and the frames will be restored and repainted. The engine will be replaced with a VW engine. The body, sheet metal, interior, bumpers, and lights will be restored or replaced with replacement parts 'and will be exactly as those original to the Volkswagen Beetles for their respective years of manufacture.' (Emphasis added.) If the operations only involved replacement of the engine and minor restoration/repair of other parts, the vehicle would be considered to be used. If, however, in addition to replacing the engine, the other operations involved replacement or 're-manufacturing' of the other parts mentioned in your letter, it would be considered a new passenger car and subject to all current safety standards, notwithstanding the fact that the old frame was retained. A new certification would also be required. I note that information that this agency has on Escargot's operations in Canada suggests that the latter category of operations may be more what that company has in mind. We have seen an advertising circular issued by The Beetles of Toronto, 'a registered tradename of Escargot Motorcars, Inc.', that boasts 'Every single piece of your Beetle is factory brand new, except one, and that's the frame.' The circular states that The Beetles places around the pan, 'all new components: engine, suspension, braking, steering, etc. The entire body is also new, as are the bucket seats, dashboard, gauges, dials, everything. Even down to the last nut and bolt.' We regard this as the manufacture of a new motor vehicle to which contemporary safety standards apply, and which must be certified by Escargot as conforming to those standards. To the extent that Escargot performed operations that are sufficiently minor that a vehicle would be considered used, it could be reimported into the United States under section 591.5(b), based on the original manufacturer's certification label. Under that section, an importer declares that the vehicle conforms to all applicable safety standards and 'bears a certification label or tag to that effect permanently affixed by the original manufacturer to the vehicle.' In the case of a used vehicle which is being reimported, we interpret the phrase 'conforms to all applicable safety standards' to refer to the vehicle at the time of its original manufacture prior to its first sale. We recognize that, because of age and use, a used vehicle typically may not continue to meet some safety standards, and did not intend that phrase to prevent reimportation of used vehicles that originally complied with all safety standards. While a used vehicle typically may not continue to meet some safety standards, the original certification label ordinarily lasts for the life of the vehicle. The certification label is the primary evidence that the vehicle was originally manufactured to meet applicable safety standards, and, in order for a used vehicle to reimported under section 591.5(b), we would ordinarily expect the certification label to present at the time of the reimportation. We recognize, however, that a certification label may be defaced or destroyed and would not, in such instance, consider absence of the certification label to an absolute bar to reimporting a vehicle under section 591.5(b). However, we would need to very carefully evaluate each factual situation on a case-by-case basis. If you have any further questions of a legal nature, you may refer them to Taylor Vinson of this Office (202-366-5263), and if they are of a technical nature, to Clive Van Orden of the Office of Enforcement (202-366-2830). Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam0411OpenMr. Donald R. Meton, System Safety Engineer, Oshkosh Truck Corporation, P.O. Box 560, Oshkosh, WI 54901; Mr. Donald R. Meton System Safety Engineer Oshkosh Truck Corporation P.O. Box 560 Oshkosh WI 54901; Dear Mr. Meton: By letter of May 11, 1971, you requested our opinion as to how Standar No. 207, Seating Systems, would apply to a seating system in which the seat belt is attached, to an eyebolt anchored on the seat frame and the eyebolt, in turn, is anchored by another length of webbing to the floor. The evident purpose of such a method attachment on suspension-type seats is to eliminate the shocks which would otherwise be transmitted to the occupant and to augment the strength of the seat, which might be unable by itself to withstand the occupant's weight in a crash.; As you correctly indicate in your letter, a system in which the belt i attached only to the floor requires a force under S4.2(a) and S4.2(b) of 20 times the weight of the seat in a forward and rearward direction, while a system with a lap belt anchored to the seat requires in addition, a force of 5000 pounds to be applied simultaneously to the seat belt in accordance with Standard No. 210 (S4.2(c)). It is our opinion that the hybrid seat belt installation shown by Oshkosh will be likely to impose significant loads on the seating system in the event of a crash, and that it should therefore be treated under S4.2(c) as a system with a seat mounted belt. The webbing running from the eyebolt to the floor is considered to be a part of the seat anchorage and should be employed during the test.; If you have further questions, please advise us. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam4452OpenC.D. Black, Engineering Manager Legislation, Compliance Product Development Jaguar Cars, Inc. 600 Willow Tree Road Leonia, NJ 07605; C.D. Black Engineering Manager Legislation Compliance Product Development Jaguar Cars Inc. 600 Willow Tree Road Leonia NJ 07605; Dear Ms. Black: This is in reply to your letters of June 8 and Octobe l7, 1987, with respect to an electrically-operated headlamp leveling system that Jaguar intends to offer on passenger cars beginning with the l989 model year. Such a device is required by EEC regulations. You have informed us that the system does not allow lamps to be adjusted above the 'zero' position, only downward to compensate for rear end loading of the vehicle. There is no provision for automatic return to the 'zero' position when the engine is turned off. Further, there will be no indication to the driver from the vehicle instrumentation that re-aim is necessary when the headlamps are adjusted downward. You have concluded, for the six reasons given in your letter of June 8 that 'no aspect of FMVSS 108 . . . is contravened by this proposed installation.' The sole restriction that Standard No. 108 imposes upon an item of motor vehicle equipment not covered by the standard but which a manufacturer wishes to add to a vehicle as original equipment is that it not impair the effectiveness of the lighting equipment that the standard requires (S4.l.3). If a manufacturer concludes that the unrequired equipment would not impair the effectiveness of the required lighting equipment, it may certify that the vehicle complies with Standard No. 108. Based on our understanding of your system, it does not appear to impair the effectiveness of the required equipment. However, we urge you to consider the possible consequences if the driver forgets to return the system to the 'zero' position from either of the two adjustment positions. These possibilities are a concern because the system does not automatically return to that position, and no warning is provided to the driver that the headlamps are not in their original design position. On the other hand, if properly used, the system could enhance headlighting effectiveness by ensuring that the headlamp provides the same lighting performance under all conditions of vehicle load. We hope the information is helpful. Sincerely, Erika Z. Jones Chief Counsel; |
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ID: aiam3397OpenMr. Norman B. Echelberry, 2514 Sherman Street, Hollywood, FL 33020; Mr. Norman B. Echelberry 2514 Sherman Street Hollywood FL 33020; Dear Mr. Echelberry: This is in response to the vehicle owner's questionnaire you forwarde on March 9, 1981, concerning the installation of computer terminals in patrol cars assigned to the city of Miami Police Department. The questionnaire was recently forwarded to my office for reply. You asked whether the installation violated any safety standards.; Federal Motor Vehicle Safety Standard No. 201, *Occupant Protection i Interior Impact*, a copy of which is enclosed, specifies performance requirements for the instrument panel. It can't be determined from the information you provided whether the terminals are located within an area of vehicle covered by that standard. The standard generally regulates only the upper portion of the dashboard. If it is located within the regulated zone, the installation of the computer terminal on the vehicle's instrument panel may be affected by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(2)(A). That section provides that:; >>>No manufacturer, distributor, dealer or motor vehicle repai business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard....<<<; Modification of the instrument panel by a manufacturer, distributor dealer or motor vehicle repair business during the installation of the computer terminals so that it no longer complies with Standard No. 201 would be a violation of section 108(a)(2)(A).; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1650OpenMr. John R. Lutz, Assistant General Counsel, Skyline Corporation, 2520 By-Pass Road, Elkhart, IN 46514; Mr. John R. Lutz Assistant General Counsel Skyline Corporation 2520 By-Pass Road Elkhart IN 46514; Dear Mr. Lutz: This is to confirm conversations you had on October 16 and 24, 1974 with Mr. Michael Peskoe of NHTSA's Chief Counsel's Office, regarding defect notification campaign 74-0149, which involves safety related defects in certain Skyline travel trailers. We wish to confirm our understanding that Skyline has agreed to send notification letters identical to that forwarded to us by your letter of October 4, 1974, to all owners of Skyline travel trailers involved in this campaign who have not at the time of mailing had their vehicles inspected, regardless of whether such purchasers were mailed a copy of an earlier notification letter.; We will consider the notification letter forwarded to us on October 4 1974, to conform to the requirements of the National Traffic and Motor Vehicle Safety Act for purposes of this particular campaign. The October 4 letter is based on our letter to you of September 23, 1974, in which we reviewed an earlier notification letter forwarded to us on September 12, 1974. However, it now appears that while we indicated certain areas in which this earlier letter failed to conform to 49 CFR Part 577, we inadvertently overlooked certain other instances in which the letter did not conform. Consequently, both the earlier letter and the letter of October 4 fail to contain information in response to the requirements of S 577.4(e)(1)(ii) and (iii). These requirements specify that the manufacturer must include an estimate of both the day by which repair parts will be available at repair facilities and the time necessary to perform the work involved in correcting the defect. The former calls for the manufacturer to specify a given day, while the latter calls for an estimate in terms of hours. While we do not request further revision of the letters sent in this campaign, these information items should be included in notifications sent in any future campaigns.; We appreciate your cooperation in the recall and repair of the Skylin trailers involved in this campaign, and trust we can rely on your continued cooperation in the future.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam0942OpenMr. R. L. Coleman, Assistant Manager, Crawford and Company Insurance Adjusters, 4915 Augusta Avenue, Post Office Box 6473, Richmond, VA 23230; Mr. R. L. Coleman Assistant Manager Crawford and Company Insurance Adjusters 4915 Augusta Avenue Post Office Box 6473 Richmond VA 23230; Dear Mr. Coleman: This is in reply to your letter of September 19, 1972, concerning a accident involving a 1972 International tractor which you maintain was not certified by its manufacturer as complying with applicable Federal standards. You state that the accident may have been due to 'insufficient gross vehicle weight'.; The Certifications regulations (49 CFR Parts 567,568) do requir final-stage manufacturers to certify the conformity of vehicles they complete, by affixing to them a label containing information specified in the regulations. In the case of vehicles manufactured on or after january 1, 1972, the regulations require that such information include a gross vehicle weight rating, and a gross axle weight rating for each axle. These ratings are set by the manufacturer based on definitional criteria found in the regulations (S 568.3, 49 CFR S 571.3). Your definition of a 'final-stage' manufacturer, 'anyone who installs a component that is not readily attachable', is correct only if the component installation is to an incomplete vehicle.; Your letter has been forwarded to our Office of Standards Enforcement who will conduct whatever investigation is appropriate to determine whether violations of NHTSA regulations have occurred. Such an investigation does not include ascertaining the cause of any accident, or whether a particular vehicle may have been overloaded. It concerns only whether the respective manufacturers have complied with NHTSA regulations applicable to them. If you wish to know the results of this investigation when it is completed, you may write our Office of Standards Enforcement, NHTSA, or call Mr. George Shifflett of that office at (202) 426-1693.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4002OpenMr. T. Chikada, Manager, Automotive Lighting Engineering Control Dept., Stanley Electric Co. Ltd., 2-9-13, Nakamegura, Meguro-Ku, Tokyo 153, Japan; Mr. T. Chikada Manager Automotive Lighting Engineering Control Dept. Stanley Electric Co. Ltd. 2-9-13 Nakamegura Meguro-Ku Tokyo 153 Japan; Dear Mr. Chikada: This is in response to your letter of June 27, 1985, to the forme Chief Counsel of this agency, Frank Berndt, asking for an interpretation regarding Figure 4-1 of Motor Vehicle Safety Standard No. 108.; With reference to a two- lamp system headlamp with two reflectors, yo have asked which of three specified Points should be regarded as the 'center of aiming pattern' within the meaning of Figure 4-1. The answer is Point B, the center of the bulb for the lower beam. NHTSA provided a clarification of this in the final rule permitting two-bulb replaceable bulb headlighting systems, published on May 22, 1985. I enclose a copy for your information. In it, the agency remarked that 'NHTSA expects the aiming pads to be located on the optical axis of the lower beam portion of the headlamp when only one light source is used for the lower beam.'; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam1200OpenMr. Stan Haransky, Associate Director, Truck Body and Equipment Association, Inc., 5530 Wisconsin Avenue, Suite 1220, Washington, DC 20015; Mr. Stan Haransky Associate Director Truck Body and Equipment Association Inc. 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Haransky: This is in reply to your letter of July 6, 1973, forwarding to us letter from Mr. Jim Finley of the Hughes Tool Company. Mr. Finley describes two situations, requesting an opinion on the applicability of NHTSA requirements to each of them.; The first question is whether an earth auger body that is mounted o crane carrier will conform to the Certification regulations (49 CFR Part 567) if the vehicle exceeds its stated weight ratings when a derrick is mounted on the vehicle but a permanent metal plate is also affixed to the vehicle which states: 'The GVWR and GAWR require that the derrick be removed before operating this vehicle upon a public highway.'; We do not believe such a label may be used to bring a vehicle int conformity with the Certification regulations. Both 'gross vehicle weight rating' and 'gross axle weight rating' call for a rating set by the manufacturer, but each is intended to reflect a fully-loaded vehicle or axle condition as vehicle is likely to be used. Although your letter is not explicit in this regard, if it is a reasonable expectation that the vehicle will be operated on the public highways with the derrick mounted on it (but for the label), even though the derrick is 'removable', we would not consider the weight ratings to be consistent with the regulations if they do not take into account the weight of the derrick.; Similarly, the components used in the manufacture of the vehicle shoul be of sufficient strength to carry the derrick when the vehicle is in motion. On the other hand, if it is unreasonable to expect the derrick to be attached to the crane carrier when the carrier is operated on the highway, the weight ratings need not take into account the weight of the derrick. In neither case, however, would the label you illustrate affect the conformity of the vehicle to the regulations, in the former case the label does not correct the incorrect weight ratings, and in the latter case, the label is unnecessary,; Your second question is whether Federal regulations regarding lightin may be met if the rear lights of a truck-mounted earth auger utilize hinged covers that are intended to protect the lights during boring operations. You state that when the vehicle is operated, the cover is secured to expose the lights. You ask if we recommend the use of a warning sticker in the cab to remind the driver to open the covers.; The use of these covers is not prohibited by the Federal lightin standard, Federal Motor Vehicle Safety Standard No. 108, 'Lights, Reflective Devices, and Associated Equipment' (49 CFR 571.108). We thInk the idea of a warning sticker in the cab is nonetheless a good one.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3728OpenMr. Buck Burwell, Vice President, Merchant's, Inc., 9073 Euclid Ave., Manassas, VA 22110; Mr. Buck Burwell Vice President Merchant's Inc. 9073 Euclid Ave. Manassas VA 22110; Dear Mr. Burwell: This responds to your recent letter to Mr. Kratzke of my staff, askin questions about a group of trucks tires you wish to sell. Specifically, your company received a large shipment of truck tires from Tong Shinn Chemical Company in Korea. Some of those tires did not have the D.O.T. symbol and other information labelled on the sidewall, as required for all new truck tires by Safety Standard No. 119, *New pneumatic tires for motor vehicles other than passenger cars (49 CFR S571.119). Your company tried to return the tires to the Korean manufacturer, because tires which do not meet the requirements of Standard No. 119 may not be legally sold in this country. However, the Korean manufacturer has gone out of business, leaving your company with $15,000 worth of tires which may not be sold legally in this country unless appropriate information is labelled on the sidewalls.; You indicated in your letter that you would be willing to label th appropriate information onto the sidewalls of the tires. Tong Shinn has indicated that those tires are of the same quality as the tires it shipped to you with the DOT markings. Further, you indicated that your company would be willing to store the names and addresses of the purchasers of these tires, in the event a safety-related recall is necessary. After considering these facts and representations, I believe you may label the tires with the necessary information and sell them, provided that you get some more information from the Korean manufacturer.; This agency has previously allowed the marking of truck tires by party other than the manufacturer in only one instance. That case, which also involved imported truck tires, included four factors which led the agency to make an exception to the policy that only a tire manufacturer can label the necessary information on the sidewall of the tires. Those factors were:; >>>(1) The manufacturer certified that the unmarked tires met th requirements of Standard No. 119, except for the labelling requirement,; (2) The manufacturer provided the appropriate information to b labelled on the tires,; (3) The manufacturer agreed to be responsible for the tires in th event of a safety-related recall, and; (4) The manufacturer agreed that the marking method to be used by th importer would not weaken the tires and destroy their compliance with Standard No. 119.<<<; In this case, Tong Shinn has already provided the first item liste above. It will be necessary for you to contact Tong Shinn to learn what information should be labelled on the tires for purposes of section S6.5 of Standard No. 119 (copy enclosed) and also the appropriate codes and information for the tire identification number, which must be labelled on the sidewalls of the tires per 49 CFR 574, *Tire Identification and Recordkeeping* (copy enclosed). Please furnish Mr. Kratzke with a copy of the information you receive from Tong Shinn on this subject.; As to the third item above, you indicate that your company would b willing to be responsible for the tires in the event of a safety- related recall. To do so, it will be necessary for your company to record the names and addresses of the purchasers of these tires, and store that information for a three year period. For further information on the responsibilities you will have to undertake, see section 574.7 for tire registration requirements for tire manufacturers.; It will also be necessary for you to contact Tong Shinn and explain ho you propose to mark the information of the sidewalls of these tires, and get them to agree that this method of marking the tires will not affect their compliance with Standard No. 119. Again, please furnish a copy of that agreement to Mr. Kratzke of this office.; After you have received this additional information, this agency has n objection to your company marking the tires and selling them. Please understand that this is permitted only because of the unique circumstances of this particular situation, and that if the Korean manufacturer had not gone out of business, you would not be allowed to mark these tires. However, in these circumstances, some flexibility in the requirements is necessary to help you avert a financial loss, while maintaining the necessary safety assurances for purchasers of these tires. If you have any further questions or need additional information, please contact Mr. Steve Kratzke of my staff at (202) 426- 2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1715OpenMr. Randall D. Bartlett, 225 Ginger Drive, Auburn, CA, 95603; Mr. Randall D. Bartlett 225 Ginger Drive Auburn CA 95603; Dear Mr. Bartlett: This is in reply to your letter of November 27, 1974, asking about th legality of rectangular headlamps, particularly with respect to the aftermarket.; Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflectiv Devices and Associated Equipment*, permits the use of a four-headlamp system with rectangular lenses of specified dimensions (approximately 4-1/4 by 6-1/2 inches), on vehicles manufactured between January 1, 1974, and August 31, 1976. The standard also permits manufacture of replacement headlamps for this system for sale in the aftermarket. The standard does not allow rectangular headlamps of other sizes, or a two-headlamp system, either as original equipment or for sale in the aftermarket.; I enclose a copy of that portion of Standard No. 108 covering th rectangular headlamps.; Yours truly, Richard B. Dyson, Acting 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.