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: nht94-3.34OpenTYPE: INTERPRETATION-NHTSA DATE: June 9, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Jerry Steffy -- Triumph Designs Ltd. TITLE: None ATTACHMT: Attached To Letter Dated 2/25/94 From Jerry Steffy To Dave Elias (OCC-9709) TEXT: Dear Mr. Steffy: This responds to your request to Mr. David Elias, formerly of this office, for an interpretation concerning whether a motorcycle certification label may be placed in a location other than that specified in 49 CFR Part 567, Certification. As explained bel ow, the answer is yes, the agency has permitted an alternative location in certain circumstances. 49 CFR @ 567.4(e) states that motorcycle certification labels "shall be affixed to a permanent member of the vehicle as close as is practicable to the intersection of the steering post with the handle bars, in a location such that it is easily readable w ithout moving any part of the vehicle except the steering system." In your letter, you seem to refer to this intersection as the "headstock area," and ask whether the certification label can be placed elsewhere. In an interpretation letter of November 23, 1982, to Suzuki Motor Co., Ltd., (copy enclosed) NHTSA permitted the motorcycle certification label to be placed "on the down tubes in front of the engine on either the right or left side." The agency permitted the alternate location because some Suzuki motorcycles were equipped with fairings, obscuring labels placed in the specified location. Your inquiry seems to imply that Triumph's design would cause a certification label placed in the location specified in @ 567.4(e) to be obscured. If that is the case, please contact Mr. George Shifflett of NHTSA's Office of Vehicle Safety 2 Compliance at (202) 366-5307. NHTSA would be happy to work with you on finding an alternative location for your certification label. I hope this information is helpful. If you have any further questions, please contact Ms. Dorothy Nakama of my staff at (202) 366-2992. Sincerely, Enclosure |
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ID: nht76-5.54OpenDATE: 02/03/76 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: U.S. Customs TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of January 12, 1976, asking about the applicability of Federal motor vehicle safety standards to motorcycles and mini-bikes. You first asked "if any motorcycles are exempt" from the National Traffic and Motor Vehicle Safety Act of 1966. If the configuration of any motorcycle is such that it cannot be licensed for use on the public roads it is considered exempt. One example is a competition cycle intended solely for racing, conveyed by trailer or truck, which has no lights, and is equipped with special tires, and gear ratios rendering it unfit for low speed on-road traffic conditions. Another is the off-road machine with knobby tires, modified suspension and gear ratios, clearly intended for trail riding, hill climbing and the like. Motorcycles with a dual off-road on-road capability are, on the other hand, subject to the Federal motor vehicle safety standards. You also asked for our "interpretation of and when a motorcycle or minibike would not be considered to have been manufactured primarily for use on the public roads." I enclose a copy of an interpretation issued in 1969 that reflects our views on this matter. As a general rule mini-bikes are not considered "motor vehicles", while most motorcycles do come within the definition. We consider both the C.B. 750 and Yamaha 90 to be "motor vehicles", even though we understand the latter is intended for dual-purpose use. Enclosed is a Statement of Compliance for motorcycles. Yours truly, Enclosures ATTACH. DEPARTMENT OF THE TREASURY U.S. CUSTOMS SERVICE GUAM January 12, 1976 Administrator -- National Highway Traffic Safety Adm., Department of Transportation Subject: National Traffic and Motor Vehicle Safety Act of 1966. I have been receiving inquiries regarding motorcycle imporations by military personnel reassigned from Japan to Guam, specifically, a C.B. 750 and Yamaha 90. Would your office please advise if any motorcycles are exempt from the subject law excluding those manufactured prior to January 1968. Also, request your interpretation of and when a motorcycle or minibike would not be considered to have been manufactured primarily for use on the public roads and is not a "Motor Vehicle" as defined in Section 102 of PL 89-563. Request a copy of the "Statement of Compliance" be furnished this office. John J. Kralik -- U.S. Customs Military Advisor |
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ID: nht75-2.15OpenDATE: 04/21/75 FROM: AUTHOR UNAVAILABLE; J. C. Schultz; NHTSA TO: Dominion Auto Accessories Limited TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of March 20, 1975, inquiring as to the permissibility of selling your "Panamirror" in the United States as aftermarket equipment. Motor Vehicle Safety Standard No. 111, Rearview Mirror, provides minimum performance requirements for rearview mirrors on passenger cars and multipurpose passenger vehicles. According to the standard, the inside rearview mirror must furnish the driver with a specified field of view to the rear of substantially unit magnification. Any vehicle manufactured for sale, sold, or introduced into interstate commerce must be equipped with an inside rearview mirror that meets the designated level of performance. It appears that the "Panamirror" would not satisfy the requirements of the provision, because it is convex in structure and therefore would not provide a view of substantially unit magnification. If the mirror were installed on a vehicle as aftermarket equipment (after the vehicle's first purchase for purposes other than resale) in such a way as to render inoperative the inside rearview mirror, section 108(a) (2) (A) of the National Traffic and Motor Vehicle Safety Act (Pub. L. 89-563) as amended (Pub. L. 93-492) would apply where the installation was accomplished by a manufacturer, distributor, dealer, or motor vehicle repair business. The section prohibits the named parties from knowingly rendering inoperative a system installed in compliance with an applicable motor vehicle safety standard. |
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ID: nht72-5.41OpenDATE: 07/19/72 FROM: CHARLES H. HARTMAN FOR DOUGLAS W. TOMS -- NHTSA TO: Stutz Motor Car of America Inc. TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of June 21, 1972. As I understand it, your company purchases Pontiac Grand Prix models for conversion into vehicles bearing the Stutz nameplate. Your converter, however, has a number of vehicles in stock, the majority of which will not be converted until after September 1, 1972. You ask, in effect, that we require compliance only with those Federal standards in effect on the date of manufacture of the original Pontiac Grand Prix, and that we do not require compliance with standards which may have come into effect after that time and before completion of the State conversion. The information contained in your letter indicates that the changes you make to the Grand Prix are confined to cosmetic changes such as alteration of the exterior sheet metal, reupholstering the interior, and replacement of the back light with glazing conforming to Standard No. 205. If the converted Grand Prix conforms to those Federal motor vehicle safety standards for which temporary exemptions was granted State (Standards Nos. 104, 201, 205, 210 and 212), we will consider it permissible for General Motors to continue to be the "manufacturer" of the vehicle for certification purposes. In that case, the date of manufacture is considered to be the date of completion by General Motors, and the original certification label should be retained on the car when converted. The vehicle must nevertheless conform at the time of sale to all safety standards and other regulations (for example, 49 CFR Part 575, Consumer Information) that are applicable on its date of manufacture. |
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ID: nht71-1.11OpenDATE: 03/29/71 FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA TO: American Motors Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of March 12, 1971, to Mr. Lewis C. Owen of this office concerning an interpretation on your lens assembly, SF-3610703. Federal Motor Vehicle Safety Standard No. 108 requires a minimum effective projected illuminated area for Class A turn signal lamps of 12 square inches on motor vehicles other than passenger cars and motorcycles. The subject lens assembly used in a turn signal lamp assembly with the opaque ornament does not appear to meet the 12 square inches minimum requirement. The calculations for the area, as determined by the method contained in our October 28, 1970, letter to Mr. E. W. Bernitt, were based on measurements of the ornament, because the detail dimensions were not supplied. The backup lamp design you discussed in a telephone conversation with Mr. Owen also apparently does not meet the requirements of FMVSS No. 108. If you would like an interpretation on this backup lamp, please furnish information on the design similar to that supplied with the subject letter. |
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ID: 07-004357asOpenMr. Mark Merchant 336 Sprague Road # 104 Berea, OH 44017 Dear Mr. Merchant: This letter responds to your note asking how to submit an idea for traffic safety on vehicles. Your device would be an addendum to the taillight currently used on most vehicles. The National Highway Traffic Safety Administration (NHTSA) issues safety standards for motor vehicles and equipment. Any interested person may recommend that NHTSA adopt a new standard or amend an existing one. Such recommendations are formally submitted via a petition for rulemaking. The requirements for petitioning for rulemaking are set forth in 49 CFR 552.4. The petition must be in the English language, the word "Petition" must be in the heading preceding the text, and the petition must set forth facts which it is claimed establish that an amendment is necessary, set forth a brief description of the substance of the amendment which it is claimed should be issued, and contain the name and address of the petitioner. Petitions must be sent to: Administrator National Highway Traffic Safety Administration 1200 New Jersey Avenue, SE, W41-307 Washington, DC 20590 We have a specific policy with respect to evaluating requests related to signal lamps, which include taillights. We believe that motor vehicle safety is best promoted by standardization of lighting signals. As you might imagine, the agency is frequently presented with new lighting ideas intended to enhance safety. Many of these are not allowable under Standard No. 108 because of deviations from the performance of the lighting equipment mandated by the standard. These ideas are often submitted without proof of their effectiveness. On December 13, 1996, we published a Federal Register notice that articulated the agency's general policy regarding new signal lighting ideas and how that policy would apply in the case of four specific brake signaling ideas (61 FR 65510). In a subsequent notice, published on November 4, 1998 (63 FR 59482), we expressed our intent to participate in efforts to develop an international consensus on how to handle new signaling ideas. We went on to say that, until a new international consensus emerges, we will follow the policy described in the December 1996 notice. I enclose a copy of both the 1996 and 1998 notices. Of particular interest to you will be the discussion on p. 65517 of the December 1996 notice in which we advised inventors to provide our Office of Research and Development with candidates for future agency research. We summarized our policy as follows: In summary, a petitioner seeking to persuade the agency to mandate a lighting invention for new vehicles bears the initial burden of establishing its safety value and cost effectiveness. The burden for those inventors seeking to make an invention optional is to convince the agency that the invention will not impair the effectiveness of required lighting equipment through creating ambiguity or negatively affecting standardization of signals. Before submitting any invention to the agency, we urge you to carefully read the enclosed Federal Register notices, and make sure that you are submitting the kind of data necessary for us to evaluate your petition. Furthermore, you should be aware of agency rules regarding disclosure of communications. If you are submitting information you would like to keep confidential, you must follow the instructions laid out in 49 CFR Part 512, Confidential Business Information. If you have any further questions, please contact Ari Scott of my staff at (202) 366-2992. Sincerely yours, Anthony M. Cooke Chief Counsel Enclosures ref:108 d.2/29/08 |
2008 |
ID: nht91-5.2OpenDATE: July 19, 1991 FROM: John D. Hayes -- Port Brokers Inc. TO: Chief Council Office TITLE: None ATTACHMT: Attached to letter dated 7-31-91 from Paul Jackson Rice to John D. Hayes (A38; Part 591) TEXT: We are anticipating handling in September an imported shipment on a Carnet basis of one DAF tractor and one trailer with a self contained jumbo video screen (27 square yards in area when completely set up) that will be used in a concert tour throughout the United States over a 30 days period of time. At the end of the 30 days period this will be completed exported. In order to be sure that we are not overlooking any important factors, we would appreciate your legal interpretation in what is necessary for this vehicle and trailer to travel throughout the United States. We understand that your form HS7 would be used and box 7 would be completed. The DAF cab is 6,900 kilos and the trailer with jumbo video screen is 26 tons. This screen costs $20,000 per day and it is extremely important that we avoid any delays which may occur regarding problems with Department of Transportation. We must respond next week to our customer in the Netherlands so that they can start working on this project. Please advise as soon as possible any particulars we need to know. We would appreciated receiving your response by fax if possible. If any other details are necessary for your interpretation please let me know. |
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ID: 1983-3.20OpenTYPE: INTERPRETATION-NHTSA DATE: 11/17/83 FROM: FRANK BERNDT -- NHTSA CHIEF COUNSEL TO: PEKKA SUURONEN -- PRODUCT DEVELOPMENT MANAGER RACEMARK INTERNATIONAL, INC. TITLE: NOA - 30 ATTACHMT: LETTER DATED 07/27/83 FROM PEKKA SUURONEN TO NHTSA TEXT: Dear Mr. Suuronen: This is in reply to your letters of July 27, 1983, and October 6, 1983, asking whether a sealed headlamp with "replaceable European H4 bulb," or "Ford bulb (6 standard sizes)" are considered "legal," (like Cibie BOBI) "provided it meets with all the applicable SAE standards." Cibie certifies that its "BOBI" headlamp complies with all applicable Federal motor vehicle safety standards, pursuant to Section 114 of the National Traffic and Motor Vehicle Safety Act. Thus far, the National Highway Traffic Safety Administration has not contested that certification. We do not understand your reference to the Ford bulb in "6 standard sizes." The only size of that bulb that may be used in the new replaceable bulb headlamp systems is the one specified in the recent amendment to Standard No. 108. However, Volkswagen has petitioned for rulemaking to allow the H4 bulb. Sincerely, |
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ID: nht74-5.23OpenDATE: 04/03/74 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Great Dane Trailers, Inc. TITLE: FMVSS INTERPRETATION TEXT: This responds to your November 1, 1973, letter and subsequent communication with Mr. Sidney Williams of the NHTSA Handling and Stability Division concerning the conformity of your trailers with Standard 121. You asked particularly about the diversion of service reservoir air for use in the air suspension unit, the location of the service reservoir check valve, and test conditions for extendable platform trailers. This will also acknowledge receipt of your March 14, 1974, petition for longer application and release time for special length trailers. The NHTSA has not issued any prohibition on the use of service brake system air in auxiliary systems such as windshield wipers and air suspensions. You may tap air from the system as long as the system still meets all the requirements listed - in particular the ability of the reservoir, when pressurized to 90 psi, to release the vehicle's parking brakes at least once. The check valve may be placed at the isolated tank to protect the trailer service reservoir as specified in S5.2.1.5, as you have detailed it in your schematic drawing. With regard to extendable platform trailers, they should be certified in the most adverse configuration. No special configuration has been specified, and the NHTSA is free to test the vehicle at any length at which it is designed to operate. The Fruehauf Corporation has also petitioned for relief from the application and release time requirement as it applies to extendable trailers. These petitions are under consideration and will be answered when that consideration is complete. |
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ID: nht71-4.9OpenDATE: 09/02/71 FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA TO: Philadelphia Newspapers, Inc. TITLE: FMVSS INTERPRETATION TEXT: In your letter of August 18 you ask for a ruling on the permissibility of wiring one filement of a clearance lamp on your small delivery truck so that it would function as a stop lamp and turn signal lamp. Federal Motor Vehicle Safety Standard Ho. 108, Lamps, Reflective(Illegible Words), does not prohibit combining a clearance lamp with a stop lamp or a turn signal lamp. However, the maximum allowable mounting height above the road surface for stop lamps is 72 inches measured from the center of the item with the vehicle at curb weight. There is currently no restriction on the maximum allowable mount(Illegible Words) however they may not be amounted higher than(Illegible Word) inches on vehicles manufactured on or after January 1, 1972. These restrictions, however, do not apply to supplemental lamps mounted higher than 72 or 88 inches, as long as a vehicle is equipped with stop lamps and turn signal lamps located within the mounting range prescribed by Standard No. 108,(Illegible Word) inches to 72 or 83 inches, as applicable, above the road surface. The Federal motor vehicle safety standards do not apply to a vehicle "after the first purchase of it for purposes other than resale." If the alterations are to be made to vehicles already in the PHI fleet, the question of the legality of your modifications would be covered by regulations of the Bureau of Motor Carrier Safety, if your vehicles are subject to them, and by State and local laws. |
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.