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: aiam3530OpenMr. Malcolm J. McCalmon, International Sales Manager, CENTRA Leichtmetall-Rader GmbH, Daimlerstrasse 6, D-6733 Hassloch/Pfalz, West Germany; Mr. Malcolm J. McCalmon International Sales Manager CENTRA Leichtmetall-Rader GmbH Daimlerstrasse 6 D-6733 Hassloch/Pfalz West Germany; Dear Mr. McCalmon: This responds to your letter to Mr. Kratzke of my staff concerning th Federal requirements for vehicle wheels that are to be imported into the United States. You noted in your letter that the wheels would be for 'original equipment on passenger vehicles and non-passenger vehicles (recreation vehicles).' There are two Federal Motor Vehicle Safety Standards which apply to wheel rims. There are no standards applicable to the rest of the wheel assembly, however.; The two applicable standards are No. 110, *Tire selection and rims passenger cars*, and Standard No. 120, *Tire selection and rims for motor vehicles other than passenger cars*. I have enclosed copies of both standards, along with Standards Nos. 109 and No. 119, which are applicable to tires. For those passenger car rims you manufacture there are two requirements, specified in section S4.4 of Standard No. 110. FIrst, the rim must be constructed to the dimensions of one of the rims that is listed under the definition of a test rim in Standard No. 109. This means that the rim must comply with the dimensional specifications shown for that rim size in the current publications of specified standardization organizations, such as the Tire & Rim Association, the European Tyre and Rim Technical Organization, or the Deutsches Institut fur Normnug. Second, in the event of a rapid loss of inflation pressure with the vehicle travelling in a straight line at 60 miles per hour, the rim must retain the deflated tire until the vehicle can be stopped with a controlled braking application.; For those rims you manufacture for use on vehicles other than passenge cars, Standard No. 120 also specifies two requirements. The first requirement, set forth in section S5.1.1, is that the rims on a vehicle must correspond with the size tire on the vehicle i.e., be listed as suitable by the tire manufacturer, pursuant to either Standard No. 109 or No. 119. This would be done in the publications of the standardization organizations, as explainted (sic) above. This requirement is the responsibility of the vehicle manufacturer, since only it knows what size tires will actually be on the vehicle. The second requirement, set forth in section S5.2, is that the rim must be marked with certain specified information.; When a rim manufacturer determines that its rims comply with th requirements outlined above, it may certify the rims and sell them in the United States. In your letter, you inaccurately stated that there is no (sic) a specific DOT certification for rims. While there is no specific DOT certification number, as required by some other standards for items for equipment other than rims, a manufacturer must always certify that each item of motor vehicle equipment complies with all applicable Federal motor vehicle safety standards, pursuant to section 114 of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1403) (copy enclosed). That section specifies that the certification for items of motor vehicle safety equipment, including rims, may be in the form of a label or tag on the item, or on the outside of a container in which the item is delivered. All of your rims to be sold in this country must contain such a certification.; The United States does not use a certification process similar to th EEC, in which the manufacturer delivers the item to be certified to the governmental entity, and that entity tests the item to determine if it can be certified. Instead, in the United States, the individual manufactuer (sic) must certify that the product complies with all applicable standards. Further, this agency does not require that a certification be based on actual tests of the equipment, we only require that the certification be made with the exercise of due care on the part of the manufacturer. It is up to the individual manufacturer to determine in the first instance exactly what data or information it needs to allow it to certify that the equipment meets all applicable Federal standards. Obviously, with respect to the requirements for rims, a manufacturer is not expected to test if the rims have the necessary markings or if the rim size is listed in one of the publications of a standardization organization.; Should you have any further questions about these standards, feel fre to contact me. If you need further information about the actual process of importing the rims into the United States or the form for the certification, you can contact the U.S. Customs Service Duty Assessment Division at 1301 Constitution Avenue, N.W., Washington, DC 20229.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2136OpenMr. W. G. Milby, Staff Engineer, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Staff Engineer Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This responds to Blue Bird Body Company's October 16, 1975, questio whether Standard No. 121, *Air Brake Systems*, preempts a State requirement that air-braked school buses be equipped with an audible and visual antilock failure warning signal and an air pressure gauge with a 3-inch display.; Standard No. 121 requires that trucks and buses be equipped with an ai pressure gauge, but it does not specify the size of the display (S5.1.4). Section S5.1.6 of the standard requires that trucks and buses be equipped with an antilock failure warning signal that is either visible within the driver's forward field of view, or both audible and continuously visible if it is not within the driver's forward field of view.; Section 103(d) of the National Traffic and Motor Vehicle Safety Act o 1966 (15 U.S.C. 1392(d)) provides that no State or political subdivision of a State may promulgate or continue in effect standards applicable to an aspect of motor vehicle or motor vehicle equipment performance which is covered by a Federal motor vehicle safety standard, unless the standards are identical.; The Federal requirements must be regarded as conclusive with regard t aspects of air brake performance covered by Standard No. 121 in order to maintain the uniformity necessary in a Federal regulatory scheme. This was affirmed in a recent decision rendered in a case brought by the Motorcycle Industry Council, Inc. against the State of California in the United States District Court for the Eastern District of California concerning the preemption of a California State requirement that motorcycle headlamps be wired to operate when the engine is running. The Court held that the California requirement is preempted by the Federal Motor Vehicle Safety Standard No. 108 since the NHTSA intended to cover all aspects of performance directly involving motorcycle headlamps.; The requirements described in your letter would be preempted b Standard 121 since the aspects of performance that would be affected are covered by the Federal standard.; You should note that this discussion of State 'requirements' onl refers to rules of general applicability within a State or municipality. It does not refer to purchase specifications that may be imposed by any person or organization, including a State or municipality, with respect to vehicles purchased for the person or organization's own use. Such specifications are not limited by Federal law, and in the case of governmental bodies are specifically allowed by S103(d), although of course they cannot alter a manufacturer's duty to conform to Federal standards.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2423OpenMr. M. P. McNiff, Global Market Planning Manager, Solar Control Products, 3 M Company, 3 M Center, Saint Paul, MN 55101; Mr. M. P. McNiff Global Market Planning Manager Solar Control Products 3 M Company 3 M Center Saint Paul MN 55101; Dear Mr. McNiff: This is in response to your September 22, 1976, letter regarding th use of 'Solar Control Reflective Films' in motor vehicles. You asked several questions concerning the applicability of Federal requirements to the manufacture and sale of your 'Scotchtint' protective film.; I am enclosing a copy of a letter to Mr. Mark T. Lerche from thi agency that discussed the applicability of Federal requirements to his company's 'Madico' solar protective film. The discussion in that letter is equally applicable to 'Scotchtint' protective film and should answer your questions. The main point to be noted is that these protective films that are attached to glass are not 'glazing' themselves and, therefore, the requirements of Federal Safety Standard No. 205 are not applicable to the manufacture of the film. It is the responsibility of the manufacturer, dealer, or vehicle repair business that applies the film to ensure that glazing remains in compliance with the standard. Of course, if your company applies the film to any glazing you would fall in this same category.; It is laudable that your company is interested in ensuring that it film is not used in a manner that would be detrimental to the safety of the motoring public. Although it is not your responsibility to do so, a safety warning to your consumers that 'Scotchtint' should not be placed on vehicle glazing in 'areas requisite for driving visibility,' would be helpful.; We appreciate your interest in motor vehicle safety. Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2073OpenMr. Naoyoshi Suzuki, Nissan Motor Co., Ltd. 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Naoyoshi Suzuki Nissan Motor Co. Ltd. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Suzuki:#This is in response to your September 16, 1975, lette to Mr. John Carson of this agency, concerning Federal Motor Vehicle Safety Standard No. 101, *Control Location, Identification and Illumination*. You requested an interpretation of the footnote to Table 1 of the standard which reads: 'Framed areas may be filled'.#The National Highway Traffic Safety Administration interprets this footnote as permitting the vehicle manufacturer the option of depicting the interior of a symbol to which it applies with the same color as the boundary of the symbol, as an alternative to depicting the interior with the same color as the background. In the hazard warning signal symbol, which consists of a triangle containing a smaller triangle, only the area between the triangles is part of the interior. The center of the small triangle is part of the background. Therefore, only the first and third of the samples submitted with your letter are permitted. For your convenience, I have enclosed a copy of the samples indicating which ones are permitted.#Sincerely, Frank A. Berndt, Acting Chief Counsel; |
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ID: aiam2589OpenMr. Don W. Vierimaa, Engineering Manager, TTMA, 2430 Pennsylvania Avenue, N.W., Washington, D.C. 20037; Mr. Don W. Vierimaa Engineering Manager TTMA 2430 Pennsylvania Avenue N.W. Washington D.C. 20037; Dear Mr. Vierimaa: This responds to your March 16, 1977, letter in which you ask for a interpretation of the certification label requirements of Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*, as they apply to trailers.; In your first question, you ask whether a trailer manufacturer ma conform with the certification requirements in any one of three ways: list the GVWR and GAWR with the corresponding tires, rims, and inflation pressure with which the trailer is equipped, list all suitable combinations with the required information as shown in the example appearing in Standard No. 120, or list only the maximum GVWR and maximum GAWR with the proper tires, rims, and inflation pressure, plus the GVWR and GAWR of the trailer with the tires, rims, and inflation pressure with which it is equipped.According to the requirements of Standard No. 120, any of the three methods outlined above would appear to be acceptable. Your second question presents a sample certification plate which lists all of the axles on the trailer. You ask whether it is permissible, where the data for all axles is identical, to list the proper tires, rims, and inflation pressure for the front axle then merely state 'Same as Front' for the remaining axles rather than repeat the same data for all axles. The label requirements of the standard do not permit the approach you suggest. You must list all data for each axle. You should note that there is a proposal to amend Part 567, *Certification*, to permit a simplification of label requirements when the data for all axles is identical. I am enclosing a copy of this proposal for your information.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3232OpenMr. Carl G. F. Pedersen, Aveco Trucks of North America, Inc., P.O. Box 1102, Blue Bell, PA 19422; Mr. Carl G. F. Pedersen Aveco Trucks of North America Inc. P.O. Box 1102 Blue Bell PA 19422; Dear Mr. Pedersen:#This is in response to your request for a interpretation of Federal Motor Vehicle Safety Standard 101-80, *Controls and Displays*. You described a bulb check button which could be activated at any time by merely pushing it in, but which when released would be automatically deactivated. You asked whether the possible activation of this button at any time would take it out of compliance with section 5.3.1 of Safety Standard 101-80.#This section states that 'a telltale shall not emit light except...during a bulb check upon vehicle starting.' This provision was intended to prevent the driver from accidently (sic) leaving the bulb check control activated and thereby creating a situation where a defective functioning of the vehicle would go unnoticed by the driver. Since the bulb check control that you described cannot accidently (sic) be left in the on position since it is deactivated when the driver releases it, section 5.3.1 of Safety Standard 101-80 would not operate so as to prohibit use of this device.#I hope that you have not been inconvenienced by our delay in sending you this response.#Sincerely, Frank Berndt, Chief Counsel; |
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ID: aiam2970OpenMr. James Tydings, Thomas Built Buses, Inc., 1408 Courtesy Road, P.O. Box 2450, High Point, NC 27261; Mr. James Tydings Thomas Built Buses Inc. 1408 Courtesy Road P.O. Box 2450 High Point NC 27261; Dear Mr. Tydings: This responds to your February 28, 1979, letter asking about th remanufacturing of vehicles using old chassis and new bodies. In particular, you ask whether these vehicles must comply with the new safety standards.; The remanufacturing operation that you mention need not comply with th new safety standards. Such a remanufactured vehicle may need to comply with the safety standards in effect on the date of manufacture of the used chassis. Otherwise, there might be a rendering inoperative of the compliance of the vehicle with the safety standards. I am enclosing a copy of an interpretation that discusses the remanufacturing issue.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam3662OpenMr. John C. Dobbs, Project Manager, E-Z-Go Textron, P.O. Box 388, Augusta, GA 30913-2699; Mr. John C. Dobbs Project Manager E-Z-Go Textron P.O. Box 388 Augusta GA 30913-2699; Dear Mr. Dobbs: This is in reply to your letter of February 4, 1983, telling of you wish to build a four-wheeled light weight traffic enforcement vehicle similar to a three-wheeled machine manufactured by Cushman. You have asked whether you have to meet passenger car safety standards 'or can we obtain a waiver for this vehicle only to comply with motorcycle safety standards?' You have enclosed a brochure on the vehicle you propose to modify, Textron's GX-800.; I am sorry to say that only vehicles with three wheels or less ar defined as 'motorcycles' for purposes of compliance with the Federal motor vehicle safety standards. Years ago, the agency totally excluded from the application of those standards four-wheeled vehicles with a curb weight of 1000 pounds or less such as the GX-800. However, that exclusion was terminated in the early 1970's.; A manufacturer of 10,000 vehicles or less per year may petition for temporary exemption from any safety standard where immediate compliance would cause substantial economic hardship. However, he must make a good faith effort to bring the vehicle into compliance during the exemption period. Although this would appear impossible with your vehicle because of its physical limitations, the agency has in the past exempted replicas of 1900-style vehicles where full compliance was manifestly not feasible. I enclose a copy of Title 49 Code of Federal Regulations Part 555 which sets out the exemption procedures. If your planned vehicle would have a cargo box, similar to the one on the Cushman vehicle, your vehicle could be considered a 'truck' for compliance purposes.; As a car or truck, your vehicle would also have to comply with Federa fuel economy and emissions standards. Exemptions from fuel economy standards may be sought under 49 CFR Part 525. As to the emissions standards, you should write the Environmental Protection Agency.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3398OpenMr. Seymour S. Weinblatt, Weinblatt & Knee, Counsellors at Law, Five Main Street, P.O. Box 985, Flemington, NJ 08822; Mr. Seymour S. Weinblatt Weinblatt & Knee Counsellors at Law Five Main Street P.O. Box 985 Flemington NJ 08822; Dear Mr. Weinblatt: This responds to your letter of March 5, 1981, in which you requested copy of Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials*. You are apparently trying to determine what types of glazing material may be used in 'caps' installed on truck bodies.; Safety Standard No. 205 specifies performance requirements for glazin materials to be used in motor vehicles and motor vehicle equipment. The standard incorporates by reference the American National Standard 'Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways,' Z26.1-1966 (ANSZ26). Copies of both standards are enclosed. ANS Z26 and Standard No. 205 list 13 'Items' or types of glazing that vary in terms of performance tests each item must pass and the locations in which each type of glazing may be used. While the meaning of the word 'cap' as used in your letter is somewhat unclear, we presume you are referring to a 'pickup cover.' A 'pickup cover' is defined in paragraph S4 of Standard No. 205 as a camper having a roof and sides but without a floor, designed to be mounted on and removable from the cargo area of a truck by the user. All 13 items of glazing may be used in pickup covers. However, some items (e.g., Item 6) may not be used in forward-facing windows, and others (e.g., Item 5) may not be used at levels requisite for driving visibility.; Certification and marking requirements for glazing are found i paragraphs S6.4 and S6.5 of Standard No. 205.; We hope you find this information helpful. Please contact this offic if you have any further questions.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0367OpenMr. Keitaro Nakajima, General Manager, Toyota Motor Co., Ltd., Factory Representative Office, Lyndhurst Office Park, 1099 Wall Street West, Lyndhurst, NJ, 07071; Mr. Keitaro Nakajima General Manager Toyota Motor Co. Ltd. Factory Representative Office Lyndhurst Office Park 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima: This is in reply to your letter of June 1, 1971, to Mr. Douglas W Tome, Acting Administrator, National Highway Traffic Safety Administration, concerning an interpretation relative to the determination of visibility of lamps.; Both of your interpretations are correct. The location of lamps an reflective devices is determined with the vehicle at its curb weight, which is the weight of a motor vehicle with standard equipment, maximum capacity of engine, fuel, oil, and coolant, and, if so equipped, air conditioning and additional weight optional engine.; The overall width is determined with 'doors and windows closed' per th interpretation of 32 F.R. 8088, June 21, 1967.; The visibility requirements for lamps and reflective devices wil therefore be determined with trunk lids, tail gates, hoods, and rear gates in the normal driving, or closed, position.; Sincerely,E. T. Driver, Director, Offices of Operating Systems, Moto Vehicle Programs; |
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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.