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: aiam2614OpenHonorable Clarence D. Long, House of Representatives, Room 200, Post Office Building, Towson, Maryland 21204; Honorable Clarence D. Long House of Representatives Room 200 Post Office Building Towson Maryland 21204; Dear Mr. Long: Your letter of May 9, 1977, to the Federal Trade Commission, on behal of Mr. Edward L. Armstrong, Sr., Baltimore, Maryland, expressing his concern that new passenger car manufacturers will discontinue supplying spare tires, has been referred to this office of the National Highway Traffic Safety Administration, Department of Transportation, for additional consideration and reply.; We believe that Mr. Armstrong's concern deals with the recentl approved 'temporary use' spare tire that will be manufactured and used with some of the new 1978 model automobiles. the use of a temporary use spare tire is not a new concept. These tires have been used with compact sport cars, such as Firebird and Camaro, since 1967. The further development of these spare tires has been fostered by the desire if the U.S. automobile manufacturers to produce small, lightweight cars in furtherance of the national energy conservation program. I am sure that you have noticed the new 1977 models by some domestic automobile manufacturers are, in fact, smaller. Of course, the development of these smaller, lightweight, energy-efficient automobiles has resulted in a substantial reduction in usable car trunk space, and therefore, providing a second reason to develop a spare tire which takes less storage space than a conventional tire.; Since this spare tire is designed for use in the nation's highways, i must conform to the minimum performance requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 109, *New Pneumatic Tires - Passenger Cars*, for strength, endurance and high speed performance, For your information, we have enclosed a copy of this standard.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam3286OpenMr. Tom Spencer, John Evans Mfg. Co., P.O. Box 669, Sumter, SC 29150; Mr. Tom Spencer John Evans Mfg. Co. P.O. Box 669 Sumter SC 29150; Dear Mr. Spencer: This responds to your May 6, 1980, telephone conversation with Roge Tilton of my staff in which you asked about the certification responsibilities for an incomplete trailer manufacturer. You indicated in your conversation that you manufacture chassis for trailers and supply them to final- stage manufacturers who complete them by the addition of a body. In particular, you asked whether you are required to comply with the provisions of Part 568.4, *Vehicles Manufactured in Two or More Stages*.; Part 568 places certain certification responsibilities upon incomplet vehicle manufacturers. The term 'incomplete vehicle' is defined in section 568.3, as an assemblage including, at a minimum, the frame, chassis structure, power train, steering system, suspension and braking system to the extent that these systems are to be part of the completed vehicle. If a chassis that you manufacture is completed to the extent that it has the above-listed components and merely needs the addition of a body by a final-stage manufacturer, it would be considered an incomplete vehicle and would be required to comply with the incomplete vehicle document requirements of Part 568. Please note that your incomplete trailer need not have all of the components listed above to be considered an incomplete vehicle subject to Part 558 (sic). It need only have those components in the list that will be found in the completed vehicle. Since your trailer is an incomplete vehicle but not a chassis-cab as that term is defined in Part 567, *Certification*, it would not be required to have a chassis-cab manufacturer's certification label attached to it.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0989OpenMr. Orin D. Miner, P.O. Box 138, Palmyra, Wisconsin 53156; Mr. Orin D. Miner P.O. Box 138 Palmyra Wisconsin 53156; Dear Mr. Miner: Contact 6 of Milwaukee, Wisconsin has sent us a copy of your lette asking that we respond to your questions.; In your letter you inquire as to the distribution of fines collecte from tire manufacturers as a result of their manufacturing tires that do not comply with the requirements of the Federal standard for passenger car tires (Standard No. 109).; Monies collected as settlement offers are transmitted to the genera funds of the United States Treasury.; The Federal Motor Vehicle Safety Standard, including the passenger ca tire standard, are minimum standards vehicle manufacturers and equipment manufacturers are required to meet. They are issued to give assurance that if the product in question meets the standards the public will have some protection against unreasonable risk of death or injury.; In addition to the question of civil penalties, manufacturers o non-conforming vehicles or tires are usually required to issue a defect notification and are urged to replace the defective equipment. Your complaint does not appear to be concerned with a safety related problem but rather with tires that you believe have not given you adequate treadwear. This is not area covered by existing standards, however, this agency has under consideration a quality grading regulation which would include grading requirements for the treadwear life of each tire manufactured after a given date.; Concerning your recommendation that Federal inspectors be placed i tire manufacturers' plants, has been considered at various times and the agency's present thinking is that the cost and manpower involved would not warrant this course of action.; Thank you for your interest in auto safety and your view in this area. Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4443OpenMr. Toshio Maeda Executive Vice President & Chief Operating Officer Nissan Research & Development, Inc. P.O. Box 8650 Ann Arbor, Michigan 48104; Mr. Toshio Maeda Executive Vice President & Chief Operating Officer Nissan Research & Development Inc. P.O. Box 8650 Ann Arbor Michigan 48104; Dear Mr. Maeda: This is in reply to your letter of June 30, 1987 asking for an interpretation of paragraph S4.1.1.36(b)(3) of Motor Vehicle Safety Standard No. 108. That paragraph specifies in pertinent part that a replaceable bulb headlamp shall be designed to conform to Section 6.1-Aiming Adjustment Test, of SAE Standard J580 AUG79 Sealed Beam Headlamp Assembly. Section 6.1.1 states that 'when the headlamp assembly is tested in the laboratory, a minimum aiming adjustment of +/-4 deg. shall be provided in both the vertical and horizontal planes.' You have asked whether the aiming adjustment is to be achieved by the headlamp assembly, or by both the headlamp assembly 'and by the headlamp when it is mounted on the vehicle.' SAE J580 applies to the design of headlamp assemblies, including the functional parts other than the headlamps, such as aiming and mounting mechanisms and hardware. The assembly may include one or more headlamps. Although the headlamp assembly is tested in the laboratory, its design must be identical to the headlamp assembly used on the vehicle. Thus, if the aiming adjustment requirement is met by the headlamp assembly in the laboratory, it should also be met when the assembly is installed on the vehicle. An individual headlamp installed on the vehicle need not meet the aiming adjustment test unless that headlamp is part of a headlamp assembly comprising only one headlamp. I hope that this answers your question. Sincerely, Erika Z. Jones Chief Counsel; |
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ID: aiam0841OpenMr. Richard Stevens, Cody Chevrolet, Inc., Barre-Montpelier Road, Montpelier, VT 05602; Mr. Richard Stevens Cody Chevrolet Inc. Barre-Montpelier Road Montpelier VT 05602; Dear Mr. Stevens: This is in reply to your letter of August 1, 1972, to the attention o Mr. Jerome Palisi of our White Plains, New York Office, concerning certification requirements for a vehicle which you describe and indicate will be used by a college to transport ball teams and school personnel, but will not be equipped with flashing lights or other special school bus equipment. You apparently wish to know whether you must consider this vehicle as a school bus for purposes of certification to Federal requirements.; 'School bus' is defined in the motor vehicle safety standards to mean bus 'designed primarily to carry children to and from school, but not including buses operated by common carriers in urban transportation of school children' (49 CFR 571.3). Based upon the description you provide, the NHTSA would not consider the vehicle you describe to be a school bus. For purposes of certification to Federal requirements (49 CFR Parts 567 and 568), therefore, 'gross vehicle weight rating' should not be computed under the minimum values specified for school buses. In addition, the requirement that vehicle type be inserted on the certification label should be met by inserting, 'BUS.'; This letter should not be construed to mean that the NHTSA takes position as to whether this vehicle need, under State law, conform to requirements for school buses. The State must determine the scope and application of its own laws.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0840OpenMr. Richard Stevens, Cody Chevrolet, Inc. Barre-Montpelier Road, Montpelier, VT 05602; Mr. Richard Stevens Cody Chevrolet Inc. Barre-Montpelier Road Montpelier VT 05602; Dear Mr. Stevens: This is in reply to your letter of August 1, 1972, to the attention o Mr. Jerome Palisi of our White Plains, New York Office, concerning certification requirements for a vehicle which you describe and indicate will be used by a college to transport ball teams and school personnel, but will not be equipped with flashing lights or other special school bus equipment. You apparently wish to know whether you must consider this vehicle as a school bus for purposes of certification to Federal requirements.; 'School bus' is defined in the motor vehicle safety standards to mean bus 'designed primarily to carry children to and from school, but not including buses operated by common carriers in urban transportation of school children' (49 CFR 571.3). Based upon the description you provide, the NHTSA would not consider the vehicle you describe to be a school bus. For purposes of certification to Federal requirements (49 CFR Parts 567 and 568), there, 'gross vehicle weight rating' should not be computer under the minimum values specified for school buses. In addition, the requirement that vehicle type be inserted on the certification label should be met in inserting, 'BUS.'; This letter should not be construed to mean that the NHTSA takes position as to whether this vehicle need, under State law, conform to requirements for school buses. The State must determine the scope and application of its own laws.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2867OpenMr. Robert B. Kurre, Director of Engineering, Wayne Corporation, P.O. Box 1447, Industries Road, Richmond, IN 47374; Mr. Robert B. Kurre Director of Engineering Wayne Corporation P.O. Box 1447 Industries Road Richmond IN 47374; Dear Mr. Kurre: This responds to your recent letter asking whether Safety Standard No 208 applies to side-facing seats in multipurpose passenger vehicle vans. You also ask to be advised of the criteria to be used for the installation of seat belts in these vehicles.; Safety Standard No. 208, *Occupant Crash Protection*, does require sid facing seats in multipurpose passenger vehicles to comply with one of the options under paragraph S4.2.2, since the side-facing seats in question would be considered designated seating positions. If a manufacturer chooses to install seat belts under one of the options of that paragraph, the seat belt assemblies must comply with Safety Standard No 209, *Seat Belt Assemblies*, and Safety Standard No. 210, *Seat Belt Anchorages*.; Safety Standard No. 210 does exempt side-facing seats from its strengt requirements, but all other requirements of the standard would be applicable. However, we strongly recommend that belt anchorages for side-facing seats be of at least equivalent strength to anchorages for forward and rearward facing seats, since the strength specifications are only minimum performance requirements. Side-facing seats were excepted from the strength requirements specified in the standard because the forces acting on side-facing seats are different from those acting on forward or rearward facing seats and the requirements and procedures were specifically developed for these latter seats.; Please contact this office if you have any further questions. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2112OpenMr. Jack A. Johnson, Chief Engineer, MOTAC, Inc (sic), 8400 East Slauson Avenue, Pico Rivera, CA 90660; Mr. Jack A. Johnson Chief Engineer MOTAC Inc (sic) 8400 East Slauson Avenue Pico Rivera CA 90660; Dear Mr. Johnson: This responds to MOTAC's September 18, 1975, question whethe rebuilding a platform trailer constitutes the manufacture of a new vehicle subject to applicable motor vehicle safety standards when the running gear (the axles, wheels, suspension, and related components sometimes known as a bogie) and the platform of a wrecked trailer is used (1) in combination with entirely new frame members, (2) in combination with one main frame member of the wrecked vehicle and one new frame member, and (3) in combination with part of one or both main frame members. You also ask whether the addition of a second axle to a single axle trailer, or the deletion of one axle on a tandem axle trailer, qualifies as the manufacture of a new vehicle subject to applicable safety standards.; In response to your first question, the National Highway Traffic Safet Administration (NHTSA) has determined (in the Stainless Tank and Equipment letter to which you refer) that, as a minimum, the running gear and main frame of the existing trailer must be used to qualify the rebuilding operation as a repair where all other materials are new. This position does not apply to the three situations you describe in which only the main frame members, and perhaps several cross members, are replaced. Therefore a repair of this type is not considered the manufacture of a new trailer.; In response to your second question, the NHTSA would not consider th addition of a second axle to a single axle trailer, or the removal of one axle from a tandem axle vehicle, to constitute the manufacture of a new vehicle.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam3580OpenMr. Ron Gustafson, Furudals Buruks Kursinternat, 790 70 FURUDUAL Sweden; Mr. Ron Gustafson Furudals Buruks Kursinternat 790 70 FURUDUAL Sweden; Dear Mr. Gustafson: This responds to your letter of June 28, 1982, asking abou requirements applicable to child restraints sold in the United States as well as any necessary permits or licenses. You also asked about any U.S. testing organizations, procedures or standards for child restraints.; All child restraints sold in the U.S. must conform with the minimu performance requirements of Federal Motor Vehicle Safety Standard No. 213, *Child Restraint Systems*. The standard also sets out the test procedures that are used to measure the performance of child restraints. There are no other performance requirements or test procedures applicable to child restraints. I am enclosing a copy of the standard.; You are not required to obtain a permit or license from this agenc prior to selling a child restraint in the U.S., nor are you required to obtain approval from any U.S. testing organization. As a manufacturer of motor vehicle equipment, you are required by Part 566, *Manufacturer Identification*, of our regulation to submit certain identifying information to the agency. I have enclosed a copy of Part 566.; In addition,m you would be required by the National Traffic and Moto Vehicle Safety Act (15 U.S.C. S1392 *et seq.*) to certify that your child restraint complies with all applicable Federal Motor Vehicle Safety Standards. Under the Act, you would also be responsible for conducting a notification and remedy campaign for any safety-related defect in your product. I am enclosing a copy of the Act, which defines your responsibilities as a manufacturer.; If you have any further question, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3974OpenThe Honorable John S. McCain, III, U.S. House of Representatives, Washington, DC 20515; The Honorable John S. McCain III U.S. House of Representatives Washington DC 20515; Dear Mr McCain: Thank you for bringing to our attention the problems experienced b your constituents due to conflicting State laws on motor vehicle window tinting.; The National Highway Traffic Administration (NHTSA) has issued Federal motor vehicle safety standard governing window tinting in new vehicles and replacement equipment, and Federal law also limits the extent to which certain commercial businesses may apply additional tinting. However, Federal law does not preclude individuals from tinting their vehicle windows. That matter is left to the States, and we understand the difficulties that may arise when the tinting laws of adjacent States are inconsistent.; Our agency has been discussing the issue of window tinting with th American Association of Motor Vehicle Administrators, in an effort to better explain the interaction of Federal and State laws in this area. That may also be an appropriate forum in which to consider ways to resolve conflicts between differing State tinting laws. While NHTSA and each state government has a valid interest in preserving its legal authority, we all share a common interest in promoting highway safety and in minimizing inconvenience to traveling motorists. In our view, a well-coordinated and cooperative approach among the various parties can help to address apparent problems in this area.; We will keep you advised of our progress in those discussions. appreciate knowing of your concern in this matter, and I hope you will feel free to contact me if this agency can be of further assistance.; Sincerely, Diane K. Steed |
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.