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: aiam2050OpenMr. William C. Koch, Assistant Attorney General for Consumer Protection, Room 419, Supreme Court Building, Nashville, TN 37219; Mr. William C. Koch Assistant Attorney General for Consumer Protection Room 419 Supreme Court Building Nashville TN 37219; Dear Mr. Koch: As you requested in your August 29, 1975, telephone conversation wit Karen Kreshover of this office, I am forwarding to you an interpretation of Section 580.5(b) of 49 CFR Part 580, *Odometer Disclosure Requirements*, as it applies to new car dealers.; Section 580.5(b) states that an odometer disclosure form need not b executed by transferors of new vehicles before their first transfer for purposes other than resale. This means that a distributor of new vehicles is not required to provide a dealer with odometer disclosure statements for vehicles he transfers to him. A new vehicle dealer, however, must complete disclosure statements for all vehicles he transfers to person who are taking possession for purposes other than reselling the vehicles. In other words, even a new vehicle which has not been previously sold to a consumer must have its odometer mileage certified in compliance with the odometer disclosure requirements when it is transferred.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam3014OpenMr. F.A. McGuirk, Jr, Wagner Electric Corp., 100 Misty Land, Parsippany, New Jersey 07054; Mr. F.A. McGuirk Jr Wagner Electric Corp. 100 Misty Land Parsippany New Jersey 07054; Dear Mr. McGuirk: I regret the delay in responding to your letter regarding Federal Moto Vehicle Safety Standard 127, *Speedometers and Odometers*. You asked which of the following digital speedometer designs was permissible under the standard: (1) A dual display, with one display expressing speeds in mph and the other in km/h, (2) a single display that alternately expresses the speed in mph and km/h, and (3) a single display that, by means of a switch, may be made to express speed in either mph or km/h.; Section 4.1.2 of the standard requires that speedometers be graduate in miles per hour and kilometers per hour. The agency interprets this requirement to mean that both systems of measurement must be simultaneously viewable by the driver. As stated in the March 16, 1978 final rule, the purpose of the dual graduation is to aid motorists in becoming acquainted with the metric system.; Only the firs design meets the requirement. the second design does no show both systems simultaneously. Further, its distracting and potentially confusing nature may draw a driver's attention away from the road for undersirably(sic) long periods of time. The third design might never serve the educational purpose underlying the dual graduations. If left switched to the mph system, as it most likely would be, the speedometer would not contribute at all to the driver; |
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ID: aiam0530OpenMr. Michael Petler, Assistant Manager, Product Development Department, U.S. Suzuki Motor Corporation, 13767 Freeway Drive, Santa Fe Springs, CA 90670; Mr. Michael Petler Assistant Manager Product Development Department U.S. Suzuki Motor Corporation 13767 Freeway Drive Santa Fe Springs CA 90670; Dear Mr. Petler: This is in reply to your letter of November 17, 1971, enclosing copie of consumer information documents you plan to use to comply with the Consumer Information requirements applicable to motorcycles. You state that you plan to place the information for particular models back to back on the same sheet of paper in order that they may correspond to your specification sheets.; The documents you have submitted, when they contain the appropriat values, will comply with the Consumer Information regulations. There is no prohibition against placing the information for two models back to back on the same sheet as you plan to do.; We are pleased to be of assistance. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0531OpenMr. Michael Petler, Assistant Manager, Product Development Department, U.S. Suzuki Motor Corporation, 13767 Freeway Drive, Santa Fe Springs, CA 90670; Mr. Michael Petler Assistant Manager Product Development Department U.S. Suzuki Motor Corporation 13767 Freeway Drive Santa Fe Springs CA 90670; Dear Mr. Petler: This is in reply to your letter of November 17, 1971, enclosing copie of consumer information documents you plan to use to comply with the Consumer Information requirements applicable to motorcycles. You state that you plan to place the information for particular models back to back on the same sheet of paper in order that they may correspond to your specification sheets.; The documents you have submitted, when they contain the appropriat values, will comply with the Consumer Information regulations. There is no prohibition against placing the information for two models back to back on the same sheet as you plan to do.; We are pleased to be of assistance. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4161OpenMr. Gary D. Clark, John Deere Tractor Works, P.O. Box 3500, Waterloo, IA 50704-3500; Mr. Gary D. Clark John Deere Tractor Works P.O. Box 3500 Waterloo IA 50704-3500; Dear Mr. Clark: This responds to your letter dated February 27, 1986, concerning you projected sale of a strip chassis for the class A motor home industry. The identifying information submitted in your letter is being referred to the Office of Vehicle Safety Standards which keeps records of manufacturer identification in accordance with 49 CFR Part 566.; Under S114 of the National Traffic and Motor Vehicle Safety Act o 1966, as amended, each manufacturer is responsible for certifying that its motor vehicles and motor vehicle equipment comply with all applicable safety standards. This agency does not require that a manufacturer's documents and test data, which form the basis for this certification, be submitted unless requested by the agency.; I hope this information is helpful to you. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3787OpenMr. Pekka Suuronen, Hella, Inc., P.O. Box 1064, Cranford, NJ 07016; Mr. Pekka Suuronen Hella Inc. P.O. Box 1064 Cranford NJ 07016; Dear Mr. Suuronen: This is in response to your letter of November 30, 1983, clarifyin your earlier requests for an interpretation of Standard No. 108. You have asked whether replaceable bulb headlamps may be manufactured in sizes identical to the current sizes for sealed beam headlamps, provided that they meet Standard No. 108 in all other respects.; The replaceable bulb headlamp amendment was adopted with the intent o allowing vehicle manufacturers greater flexibility in the front end design in order to improve aerodynamics. The amendment allows an original equipment two-lamp system of no specified dimensions, and replacement lamps for these systems. It was not directed towards replacement lamps for existing headlamp systems. However, because no exterior dimensions for headlamps are specified by the amendment, replaceable bulb headlamps intended for use in a two-lamp system, with exterior dimensions of sealed beam round or rectangular two-headlamp systems, would be permissible assuming that they meet all other requirements of Standard No. 108, including proving one of the two aiming pad locations specified for replaceable bulb headlamps. However, until Standard No. 108 is amended to allow a four-lamp replaceable bulb headlamp system, these lamps are precluded from being manufactured to replace today's sealed beam round and rectangular sealed beam headlamps used in four-lamp systems.; I hope this provides the clarification you seek. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0069OpenMr. R.R. McLain,Sales Manager,Royal Brass, Inc.,442 Arlington Avenue,Fond Du Lac, Wisconsin 54935; Mr. R.R. McLain Sales Manager Royal Brass Inc. 442 Arlington Avenue Fond Du Lac Wisconsin 54935; Dear Mr. McLain:#Thank you for your letter of April 26, 1968 concerning certification of brake hoses. Hydraulic brake hoses for use in passenger cars and multipurpose passenger vehicles manufactured after January 1, 1968 must comply with Federal Motor Vehicles Safety Standard No. 106, Hydraulic Brake Hoses - Passenger Cars and Multipurpose Passenger Vehicles.#At the time of delivery of the completed brake hose assembly to a distributer or dealer the manufacturer of the completed brake hose assembly must certify that it complies with the applicable standard. In the case of equipment such as the brake hose assembly the certification may be in the form of a label or tag on the completed brake hose assembly delivered.#For your information I have enclosed a copy of the Federal Motor Vehicle Safety Standards, the notice published in the *Federal Register* concerning certification and a copy of the National Traffic and Motor Vehicle Safety Act of 1966. Particular attention should be paid to the sections 108 and 114 of the Act.#I hope this letter and the enclosures are adequately responsive to your questions. #Sincerely,Robert M O'Mahoney,Assistant Chief Counsel; |
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ID: aiam1182OpenMr. Gorou Utsunomiya, Branch Manager, 23777 Greenfield Rd., Southfield, Michigan 48075; Mr. Gorou Utsunomiya Branch Manager 23777 Greenfield Rd. Southfield Michigan 48075; Dear Mr. Utsunomiya: This is in reply to your letter of June 11, 1973, regarding th application of section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C S1403) to Motor Vehicle Safety Standard No. 107, 'Reflecting Surfaces'. You refer to language in a letter dated April 10, 1973, from this agency to Mr. Kazushi Sakashita of Toyo Kogyo., Ltd., in which we indicated that certification of replacement vehicle parts pursuant to section 114 is required only with respect to parts to which a safety standard specifically applies.; Standard No. 107 applies to motor vehicles--passenger cars multipurpose passenger vehicles, trucks, and busses (paragraph S2 of Standard No. 107)-- and not to items of motor vehicle equipment. Consequently the certification of conformity to the standard required by section 114 is accomplished by the label affixed to each vehicle in accordance with 49 CFR Part 567, 'Certification'. That label represents a certification of conformity to all standards, including Standard No. 107, applicable to the vehicle. There is no requirement that the individual components listed in S4 of the standard, i.e. the windshield wiper arms and blades, the inside windshield moldings, the horn ring and hub of the steering wheel assembly, and the inside rearview mirror frame and mounting bracket, be certified independently.; Your truly, Richard B. Dyson, Assistant 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: aiam0201OpenMr. 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 |
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.