Departamento de Transporte - USNHTSA 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: aiam5182OpenJohn Paul Barber, Esq. Legislative Counsel American Association of Blood Banks 8101 Glenbrook Road Bethesda, Maryland 20814-2749; John Paul Barber Esq. Legislative Counsel American Association of Blood Banks 8101 Glenbrook Road Bethesda Maryland 20814-2749; Dear Mr. Barber: This responds to your letter asking whether secon stage manufacturers may affix additional certification labels with a new gross vehicle weight rating (GVWR) on vehicles. You asked this question in the context of the Federal Highway Administration's commercial driver's license program which applies in part to commercial vehicles with a GVWR of 26,001 pounds or more. You stated in your letter that your organization has advised its members that second stage manufacturers that convert buses to bloodmobiles have the authority under 49 CFR Parts 567 and 568 to affix an additional label with a new GVWR to newly converted vehicles as well as to vehicles already in use. You stated, however, that you have since received a legal opinion from a private party asserting that those regulations preclude affixing an additional label to vehicles already in use. You enclosed a copy of your earlier advice (American Association of Blood Banks Bulletin; "92-5), which reads in part as follows: Many bloodmobiles have a gros vehicle weight rating of 26,001 or more pounds. This renders the bloodmobiles commercial motor vehicles requiring an operator with a commercial driver's license. However, options may be available to avoid the classification of bloodmobiles as commercial motor vehicles on the basis of their gross vehicle weight rating. . . . When originally constructed, buses will be given gross vehicle weight ratings in excess of 26,000 pounds. When converted for use as bloodmobiles, their actual weight is reduced to two or three thousand pounds less than the 26,000 pound threshold, yet many converters do not change the gross vehicle weight rating. By federal regulation, vehicle converters have the authority to affix an additional label containing a new gross vehicle weight rating, to newly converted vehicles as well as to vehicles already in use. Title 49 Code of Federal Regulations, Sections 567 and 568. I am pleased to have this opportunity to explain our regulations to you. By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized by the National Traffic and Motor Vehicle Safety Act (Safety Act) to issue safety standards applicable to new motor vehicles and new motor vehicle equipment. NHTSA does not, however, approve motor vehicles or motor vehicle equipment. Instead, under the Safety Act, manufacturers are required to certify that their products meet all applicable safety standards. I will first discuss the issues you raise concerning new vehicles. Under NHTSA's certification regulations (Parts 567 and 568), manufacturers must assign a GVWR to a new vehicle. The term GVWR is defined in 49 CFR Part 571.3 as 'the value specified by the manufacturer as the loaded weight of a single vehicle.' The GVWR informs vehicle owners how heavily the vehicle may safely be loaded. It also affects the vehicle's loading and other test conditions for the safety standards to which the vehicle must be certified, and at which NHTSA conducts any compliance testing. NHTSA expects the GVWR to reflect a manufacturer's good-faith evaluation of the vehicle's size, weight and load carrying capacity. The only express regulatory limitation on the GVWR that manufacturers may assign to their vehicles is set forth in 49 CFR Part 567. Section 567.4(g)(3) provides that the assigned GVWR 'shall not be less than the sum of the unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity.' See also section 567.5. You asked about the authority of persons who convert buses to bloodmobiles to reduce the GVWR of the vehicle. I note that, assuming that the conversion takes place before the first sale of the vehicle for purpose other than resale, i.e., while the vehicle is still new, the converter would be considered either a 'final stage manufacturer' or an 'alterer,' depending on the circumstances. A final stage manufacturer is a person who performs such manufacturing operations on an incomplete vehicle that it becomes a complete vehicle. See 49 CFR Part 568.3. An alterer is a person who modifies a previously certified, new motor vehicle. See 49 CFR Part 567.6, 567.7, and 568.8. A final stage manufacturer is ordinarily responsible for making the final assignment of GVWR for a vehicle that it completes. See 49 CFR Part 567.5(c). (Special requirements apply if the incomplete vehicle manufacturer or an intermediate vehicle manufacturer assume legal responsibility for all duties imposed by the Safety Act.) However, as discussed below, a final stage manufacturer may, as a practical matter, need to assign to the completed vehicle a GVWR that is consistent with that specified by the incomplete vehicle manufacturer. Incomplete vehicle manufacturers (typically GM, Ford or Chrysler) are required to furnish with the incomplete vehicle a document which specifies, among other things, the GVWR of the completed vehicle for which the incomplete vehicle is intended (i.e., the GVWR that is appropriate for the incomplete vehicle when completed) and statements concerning how the design of the incomplete vehicle affects conformity with safety standards. See 49 CFR Part 568.4. Moreover, manufacturers of chassis-cabs are required also to attach a certification label concerning the conformance of the chassis-cab with safety standards. See 49 CFR Part 567.5(a). (A chassis-cab is an incomplete vehicle, with a completed occupant compartment, that requires only the addition of cargo-carrying, work- performing, or load-bearing components to perform its intended function.) If a final stage manufacturer wishes to base its certification on the incomplete vehicle document or other information furnished by the incomplete vehicle manufacturer, as the vast majority of final stage manufacturers do in actual practice, the final stage manufacturer will likely need to assign to the completed vehicle a GVWR that is consistent with that specified by the incomplete vehicle manufacturer. I note that, since most safety performance requirements are easier to meet at lower loads than higher loads, it is possible that a final stage manufacturer might be able to justify assigning a reduced GVWR to some vehicles. We would urge the final stage manufacturer to consult with the incomplete vehicle manufacturer about such an action. As indicated above, the reduced GVWR would need to comply with the requirement set forth in 49 CFR Part 567.4(g)(3), and we would expect it to reflect the manufacturer's good-faith evaluation of the vehicle's size, weight and load carrying capacity. I note that the final stage manufacturer is subject to the same basic requirements concerning GVWR as a single stage manufacturer. I have enclosed a copy of an April 29, 1991 letter to Mitsubishi which discusses the issue of reducing the GVWR of certain vehicles. An alterer has a more limited certification responsibility. Under 49 CFR Part 567.7, an alterer must allow the original certification label to remain on the new vehicle and must affix an additional label which states that, as altered, the vehicle 'conforms to all applicable Federal Motor Vehicle Safety Standards affected by the alteration.' If the GVWR of the vehicle as altered is different from that shown on the original certification label, the modified value must be provided. I note, however, that since an alterer only certifies a vehicle with respect to the alterations it makes, the alterer would only have a basis to change the GVWR if the alterations are relevant to GVWR. You also asked whether manufacturers may affix additional labels with a new GVWR to vehicles after they are sold for purposes other than resale, i.e., after they become used vehicles. As discussed above, the term GVWR refers to 'the value specified by the manufacturer as the loaded weight of a single vehicle,' and the GVWR is assigned by the vehicle's manufacturer as part of the certification process. Therefore, for purposes of NHTSA's regulations, a vehicle's GVWR is fixed as of the time of its first sale to a consumer. The only exception to this is if the manufacturer seeks to correct an error (e.g., calculation error or typographical error) regarding the originally assigned GVWR. We recognize that certain modifications that might be made to a used vehicle (e.g., adding or deleting an axle) could make the originally assigned GVWR inappropriate for the vehicle as modified. While not required by our regulations, we believe it would be appropriate in such situations to add a label to the vehicle which indicates the appropriate loaded weight of the modified vehicle. You also asked whether the affixing of a new label with an adjusted GVWR would have the effect of rendering existing bloodmobiles noncommercial motor vehicles for purposes of the Commercial Motor Vehicle Safety Act. Since the commercial driver's license program is administered by the Federal Highway Administration (FHWA), I have referred this question to that agency. If you wish to speak to someone at that agency about your question, you may contact Charles Medalen, of the FHWA Office of Chief Counsel, at (202) 366-1354. I hope this information is helpful. If you have any further questions about NHTSA's regulations, please feel free to contact Edward Glancy of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure "; |
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ID: aiam5028OpenMr. Joe Wos A & D Lock & Key 238 Faithway Dr. Seffner, FL 33584; Mr. Joe Wos A & D Lock & Key 238 Faithway Dr. Seffner FL 33584; Dear Mr. Wos: This responds to your May 26, 1992 letter asking whethe it is 'legal to repair an automobile that has an airbag deployed and not put the air bag back in.' I am enclosing a copy of a January 19, 1990 letter to Ms. Linda L. Conrad, that explains whether a used car dealer has an obligation to replace a deployed air bag prior to selling the car. The same statutory and regulatory considerations that applied to that situation would apply to the replacement of a damaged air bag steering column (after the air bag has deployed) with a steering column without an air bag. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosure; |
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ID: aiam2217OpenMr. John B. White, Engineering Manager, Technical Information Dept. Michelin Tire Corporation, P.O. Box 3467, New Hyde Park P.O., New York 11040; Mr. John B. White Engineering Manager Technical Information Dept. Michelin Tire Corporation P.O. Box 3467 New Hyde Park P.O. New York 11040; Dear Mr. White: #This is in response to your letter of January 27 1976, concerning the rim listing requirements of Federal Motor Vehicle Safety Standards No. 109 and 110. #You wish to designate the 15x5.5JJ rim a permissible for use with tire sizes 225-15 and 230-15. You have requested confirmation of your interpretation that you need merely list the rim in a document that is furnished to your dealers, to any person on request, and in duplicate to the Tire Division of the NHTSA. Your interpretation is correct. Please note, however, that this listing must include dimensional specifications and a diagram of the rim, unless each of the association publications referred to in S4.4.1(b) of Standard No. 109 in which the rim is listed already contains such specifications and diagram. #We hope that you will also ensure that this tire-rim combination is listed in one of those publications as soon as is possible. #Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
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ID: aiam1591OpenMr. David E. Martin,Director, Automotive Safety Engineering,General Motors Corporation,General Motors Technical Center,Warren, Michigan 48090; Mr. David E. Martin Director Automotive Safety Engineering General Motors Corporation General Motors Technical Center Warren Michigan 48090; Dear Mr. Martin:#This responds to your letter of August 14, 1974 requesting an interpretation of Motor Vehicle Safety Standard No. 106-74, *Brake Hoses* (Docket 1-5, Notice 11, published on June 28, 1974), regarding its applicability to specific hydraulic brake booster hoses used in General Motors products.#As indicated in notice11, it is the National Highway Traffic Safety Administration's (NHTSA) intention to exempt from the requirements of the standard hydraulic booster lines subject to a different working environment than brake hose, pending development of special performance requirements for such lines. General Motors' interpretation that the hydraulic booster hoses used in the systems described in your August 14 letter are exempted from the standard requirements is correct. The system described in your Attachment A is considered to incorporate an accumulator integral with the brake booster assembly. Hence all of the hoses run between the power steering pump and the accumulator (either directly or via the power steering gear) and are accordingly exempted per Notice 11 preamble. The hoses used in the system described in your Attachment B are exempted by virtue of the provision of redundant booster poser by the independent electro-hydraulic pump.#a future amendment to FMVSS 106 to eliminate ambiguity in respect to the standard's applicability to hydraulic booster hoses is currently under consideration. Any such amendment will be consistent with the present interpretation.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam4269OpenMr. Bruce Torrey, Product Performance Specialist, General Electric Company, One Plastic Avenue, Pittsfield, MA 01201; Mr. Bruce Torrey Product Performance Specialist General Electric Company One Plastic Avenue Pittsfield MA 01201; Dear Mr. Torrey: Thank you for your letters of August 13, and 26, 1986, concerning ho the requirements of Standard No. 205, *Glazing Materials*, apply to glazing materials installed in the side windows of some New York City Transit Authority (NYCTA) buses. As explained below, the information you provided in your letters and in your phone conversations with Stephen Oesch of my staff and the information provided by NYCTA in a June 19, 1986 letter to the agency indicates the glazing materials installed in the NYCTA buses do not comply with the marking requirements of the standard.; You explained in your letter that the glazing material used in the sid and standee windows in the buses is Lexan sheet, which is a plastic material manufactured by General Electric. According to your letter the Lexan glazing material used in these windows can meet all of the performance requirements set in Standard No. 205 for 'AS-5' glazing materials. However, the material apparently was not marked as 'AS-5' material, but may have instead been marked 'AS-4/6.' (Information provided to the agency by the NYCTA in June 1986 indicates that the windows did not contain any 'AS' number. At the time of your phone conversation with Mr. Oesch, you had not been able to confirm what markings, if any, had been placed on the glazing material by General Electric).; Standard No. 205 specifies performance and location requirement fo glazing used in new vehicles and glazing sold as replacement equipment. (The various types of glazing are designated as 'items' in the standard). Plastic glazing materials, such as Lexan, can be used in a number of different locations in a bus depending on which performance requirements the glazing meets. If the plastic glazing meets the requirements set AS-5 glazing materials, it can be used in any window in a bus, except for the windshield, windows to the immediate right and left of the driver and the rearmost windows if used for driving visibility.; In addition to setting performance requirements for different items o glazing, the standard requires glazing materials to contain certain markings. The marking requirements of S6 of the standard vary depending on the intended use of the glazing and the person that is marking the glazing. At a minimum, the standard requires the glazing to be marked with the AS number (which indicates that the material meets the performance requirements set for that 'item' of glazing material), a model number and the manufacturer's logo. The information the agency has received about the markings on the glazing installed in the NYCTA buses indicates that the glazing does not have an AS number marked on it.; Any glazing sold for use in a motor vehicle must conform to th applicable requirements of Standard No. 205. Since there appears to be an apparent noncompliance, General Electric is required by Part 575 of our regulations to file a report with the agency providing additional details about the noncompliance and General Electric's plans to remedy the noncompliance. As you requested Mr. Oesch, I am also enclosing a copy of the agency's regulation concerning the filing of a petition for a determination that a noncompliance is inconsequential.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4793OpenMr. Hiroshi Kato Vice President Mitsubishi Motors America, Inc. Suite 1960 3000 Town Center Southfield MI 48075; Mr. Hiroshi Kato Vice President Mitsubishi Motors America Inc. Suite 1960 3000 Town Center Southfield MI 48075; Dear Mr. Kato: This is in reply to your letter of September 4, l990 asking for an interpretation of paragraph S5.1.3 of Standard No. 108 with respect to two of Mitsubishi's contemplated rear lighting plans. In the first plan, the rear garnish panel located between the lamps that are mounted at the right and left extremities of the car would be dark but the word 'Mitsubishi' in the center would be illuminated. In the second plan, the panel would be illuminated as a supplemental taillamp, and the word would not. You ask if either plan would create an 'impairment' of the required lighting equipment, within the prohibition of S5.1.3. Judging by the photograph of the Pontiac Fiero that you enclosed, which featured a design similar to your first plan, it does not appear that this plan would create an impairment. We note that the backup lamp is located in the garnish panel, approximately l5 mm from the word 'Mitsubishi', and this raises a question with respect to the second plan. When the taillamps are illuminated, so that there is a broad sweep of red light across the rear of the car, we would be concerned that the backup lamps in the garnish panel might not be readily perceived when activated. We would also be concerned that the illuminated panel might detract from the effectiveness of the stop lamps when they are activated. To ensure that the lighted panel creates no impairment of either the stop lamps or the backup lamps, it might be advisable to design it with an intensity that is lower than that of the adjacent taillamps. The determination of impairment is to be made by the vehicle manufacturer in its certification that the vehicle complies with all applicable Federal motor vehicle safety standards. Unless that determination appears clearly erroneous, NHTSA will not question it. I hope that this answers your question. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam3056OpenMichael J. Schmitt, Esq., Legal Counsel, Engineering Division, Yamaha Motor Corporation U.S.A., P.O. Box 6555, Cypress, CA 90630; Michael J. Schmitt Esq. Legal Counsel Engineering Division Yamaha Motor Corporation U.S.A. P.O. Box 6555 Cypress CA 90630; Dear Mr. Schmitt: This is in reply to your letter of July 2, 1979, to our former Chie Counsel, Joseph Levin asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108.; You have quoted Column 3 of Table IV with respect to motor cycl headlamps and the specification that the one headlamp the standard requires be located 'on the vertical centerline, except that if two are used they shall be symmetrically disposed about the vertical centerline'. Yamaha would like to equip certain motor cycles with two headlamps, one to be mounted above the other on the vertical centerline with the hope that 'this may increase conspicuity and facilitate safety'. You have asked whether this mounting arrangement conforms with Standard No. 108.; The arrangement you have in mind is not permitted by the Federa lighting standard. 'Symmetrically disposed about the vertical centerline' means that each headlamp is an equal distance from the vertical centerline at the same horizontal location. We believe that this provides better and more evenly distributed forward illumination than the system Yamaha proposes, while being the equivalent in conspicuity.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4639OpenMr. Russell Storms Luke Grimm 2140 SW Pallatwe Street Portland, Oregon 97219; Mr. Russell Storms Luke Grimm 2140 SW Pallatwe Street Portland Oregon 97219; "Dear Mr. Storms: This responds to your letter asking that thi Department 'approve' or otherwise 'recognize' your newly invented warning device. I apologize for the delay in this response. In your letter, you described your invention as a seven inch high, tetrahedral reflective traffic marker that is non-flammable and easily stored. I am pleased to have this opportunity to explain our law and regulations to you. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., the Safety Act) gives this agency the authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. We have exercised this authority to establish Standard No. 125, Warning Devices (49 CFR 571.125, copy enclosed). This standard specifies performance requirements and test procedures for warning devices that are designed to be carried in motor vehicles and used to warn approaching traffic of a stopped vehicle. Based on the description in your letter, your newly invented product appears to be a warning device subject to Standard No. 125. When the agency has issued an applicable safety standard, section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) provides that no person shall 'manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States' any new motor vehicle or new item of equipment unless the vehicles or equipment are in conformity with the applicable standard. Assuming your product is subject to Standard No. 125, it must conform to all the requirements of that standard. You are not required to get some 'approval' or 'recognition' from this agency before selling this product. In fact, NHTSA has no authority under the Safety Act to approve, certify, or otherwise endorse any commercial product. Instead, section 114 of the Safety Act (15 U.S.C. 1403) establishes a self-certification process under which every manufacturer is required to certify that each of its products meet all applicable Federal safety standards. Therefore, the manufacturer of this new product must certify that it conforms to all applicable standards. Section 108(b)(2) of the Safety Act (15 U.S.C. 1397(b)(2)) requires the manufacturer of this new warning device to exercise 'due care' in certifying that it conforms to Standard No. 125. To comply with these legal obligations, I suggest that you carefully examine the requirements of Standard No. 125 and determine if this new product conforms with those requirements. As you will see, Standard No. 125 contains specific requirements related to a warning device's material, container, labeling, configuration, color, reflectivity, luminance, stability, and durability. In particular, you should be aware that section S5.2.2 of the standard requires that: each of the three sides of the triangular portion of the warning device shall not be less than 17 and not more than 22 inches long, and not less than 2 inches and not more than 3 inches wide. Your letter states that your new warning device is seven inches in height. If that is the case, the new warning device would not comply with the requirements of Standard No. 125. You should further compare your proposed design with the other requirements in Standard No. 125 to determine if your new warning device complies with all of the other provisions. You should be aware that the Vehicle Safety Act establishes a civil penalty of $1,000 for each violation of a safety standard and a maximum penalty of $800,000 for a series of violations. In addition, the Act requires manufacturers to remedy their products if they fail to comply with any applicable safety standards. If you have any further questions or need additional information on this subject, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosure"; |
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ID: aiam3406OpenMr. H. Hayashi, Manager for Safety Standards, Tire Quality Assurance Dept., Bridgestone Tire Co., Ltd., 2800-1, Ogawa, Higashi-Cho, Kodairai-Shi, Tokyo, JAPAN; Mr. H. Hayashi Manager for Safety Standards Tire Quality Assurance Dept. Bridgestone Tire Co. Ltd. 2800-1 Ogawa Higashi-Cho Kodairai-Shi Tokyo JAPAN; Dear Mr. Hayashi: This is in response to your letter of March 26, 1981, requesting, (sic an interpretation of the Uniform Tire Quality Grading (UTQG) Standards (49 CFR S575.104). You ask whether a tire designed for service as a temporary use spare tire, and labeled on its sidewall with the inscription: TEMPORARY USE ONLY FOR SPARE TIRE, INFLATE TO 40 PSI, MAX. SPEED 50 MPH, is exempt from the requirements of the UTQG Standards.; As you note, the 'Application' section of the UTQG regulation does no apply to space-saver or temporary use spare tires. Thus, the UTQG Standards would not apply to the tire you describe, which is designed as a temporary use spare tire and is so labeled.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3113OpenMs. Mary Ann McClure, Bob Maxant's Illinois Harley-Davidson Sales, Inc., 6510 Roosevelt Road, Oak Park, IL 60304; Ms. Mary Ann McClure Bob Maxant's Illinois Harley-Davidson Sales Inc. 6510 Roosevelt Road Oak Park IL 60304; Dear Ms. McClure: This responds to your letter asking how long you should retain certai records relating to the sale of motorcycles and motorcycle parts.; The National Highway Traffic Safety Administration (NHTSA) has som record retention requirements that apply to manufacturers of motor vehicles and motor vehicle equipment. Dealers are required to aid manufacturers in the maintenance of their records. For example, you must supply manufacturers with information relating to the purchasers of motor vehicles that you sell so that the manufacturer can maintain a list of purchasers.; Dealers are not required by the NHTSA to maintain records on vehicle or equipment they sell. Accordingly, with respect to the records indicated in your letter, you may use your own business judgment as to when to dispose of them.; Sincerely, Frank Berndt, Chief Counsel |
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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.