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 |
|---|---|
ID: nht79-1.7OpenDATE: 10/24/79 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: VDO-ARGO Instruments Inc. TITLE: FMVSS INTERPRETATION TEXT: NOA-30 Mr. H. A. Ritzenthaler VDO-ARGO Instruments Inc. 980 Brooke Road P.O. Box 2630 Winchester, Virginia 22601 Dear Mr. Ritzenthaler: This is in response to your letter of January 25, 1979, in which you stated your interpretation of Federal Motor Vehicle Safety Standard 127, Speedometers and Odometers, and asked that we advise you if action taken in accordance with this interpretation would place your company in violation of the standard. This letter is to confirm that your interpretation is correct. According to your interpretation of Safety Standard 127, those provisions which become effective for new motor vehicles on September l, 1979 and September 1, 1980 are not applicable to speedometers and replacement parts produced for use in motor vehicles manufactured before those dates. This is correct because Safety Standard 127 is a vehicle standard and an equipment standard which applies to passenger cars, multipurpose passenger vehicles, trucks, motorcycles, and buses manufactured after the standard's effective dates and to speedometer and odometers for use in such vehicles. (Section 3, Safety Standard 127). Sincerely, Frank Berndt Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Admin. 300 Seventh Street S.W. Washington, D.C. 20590 January 25, 1979 ATT: Mr. Richard B. Dyson, Acting Chief Counsel Dear Mr. Dyson: We are a manufacturer of automotive instruments, including speedometers. The changes required on speedometers for new cars after the effective dates September 1979 and September 1980 are clearly defined in Regulation 127, and our original equipment speedometers will be in compliance with this regulation. We also have an obligation toward the automotive industry to supply original replacement parts for a period of ten years after manufacture of a particular vehicle model has ceased. These replacement parts for cars manufactured before the effective dates of Regulation 127 would, of course, not embody the changes called for in Regulation 127, nor does the regulation itself require such modifications in reference to replacement parts. This is our interpretation of the applicability of Regulation 127. Should you feel that this interpretation would put us in violation of Regulation 127, please advise us accordingly. Sincerely, VDO-ARGO INSTRUMENTS, INC. H. A. Ritzenthaler Manager, Engineering HAR/nf |
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ID: nht88-1.1OpenTYPE: INTERPRETATION-NHTSA DATE: 01/01/88 EST FROM: KATHLEEN DEMETER -- ASSISTANT CHIEF COUNSEL FOR GENERAL LAW, NHTSA TO: ROBERT G. YORKS -- VICE PRESIDENT AND GENERAL MANAGER, AUTOMOTIVE BUSINESS GROUP, TRUCK-LITE CO. TITLE: NONE ATTACHMT: ATTACHED TO MEMO DATED 8-1-88, FROM ERIKA Z. JONES, TO ROBERT G. YORKS, STD 108, REDBOOK A32; ALSO ATTACHED MEMO DATED 5-24-88, TO KATHLEEN DEMETER FROM ROBERT G. YORKS, 25220 TEXT: In a letter dated March 31, 1988, you requested our interpretation as to whether a new motor vehicle device would comply with applicable Federal Motor Vehicle Safety Standards. You also asked that the description, general design concept, and details of the device be afforded confidential treatment. Please be informed that this agency requires all of its interpretations to be made publicly available. Hence, you must decide if you still desire a interpretation to be issued in this matter, with the result that the confidential status of the informati on will be compromised. I am prepared to delete any information specifically identifying you or your company from our analysis if you so request, but the substantive information describing the item of motor vehicle equipment will be made part of the pub licly available analysis. No further action will be taken in this matter until we have received a response from you. |
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ID: cowley.ztvOpenMr. Vance B. Cowley Dear Mr. Cowley: This is in reply to your recent letter asking about the "placement and quantity of marker lamps required on a truck" your company is manufacturing. The overall length of the truck is 31 feet 6 inches. You have provided two drawings depicting the lamps presently installed and would like us to indicate where any additional lamps and reflectors should be located, and the color of such lamps and reflectors. I enclose a copy of Federal Motor Vehicle Safety Standard No. 108, and a chart "Federal Lighting Equipment Location Requirements" applicable to trucks, buses, and multipurpose passenger vehicles, which was jointly issued by the National Highway Traffic Safety Administration and Transport Canada. These will provide you with the requirements relating to the number and location of all lamps and reflectors on your truck. Among other things, Standard No. 108 requires rear identification and clearance lamps to be mounted on the rear of a truck, not the rear of the truck cab. Furthermore, intermediate side marker lamps are required to be amber, not red. Your drawings appeared to deviate from these requirements. If you have any questions about the chart in connection with your design, you may call Rich Van Iderstine in our Office of Rulemaking (202-366-2720). Sincerely, Z. Taylor Vinson Enclosures |
1970 |
ID: 11698.ZTVOpen M. Guy Dorleans Dear M. Dorleans: We have received your letter of March 19, 1996, asking for an interpretation of paragraphs S7.2(a) and S7.5(g) of Motor Vehicle Safety Standard No. 108. These paragraphs require that lenses of replaceable bulb headlamps be marked with the DOT symbol and the HB-type of light source used in the headlamp. Your engineers contemplate a clear-lensed headlamp, and would like to engrave these markings on a visible area of the inner bezel where they are easily seen from the outside. You ask for confirmation that this would meet the "spirit" of the requirement even if the definition of lens doesn't apply to an interior part. The Federal motor vehicle safety standards specify objective requirements. Failure to mark the lens in the manner specified by Standard No. 108 would create a noncompliance with the standard. Paragraphs S7.2(a) and S7.5(g) are very specific in their requirements that the lens be marked, and do not allow alternative marking of the bezel if the lens is clear. If you have any questions, you may refer them to Taylor Vinson of this Office (FAX 202-366-3820). Sincerely, Samuel J. Dubbin Chief Counsel ref:108 d:4/25/96 |
1996 |
ID: nht73-6.7OpenDATE: 05/16/73 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Hayden; Smith; Ford & Hays TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of April 30, 1973, requesting our opinion as to the conformity with 49 CFR Part 577, "Defect Notification", of a defect notification letter to be mailed by your client, V/M Custom Boat Trailers. The notification fails to conform with Part 577 in the following ways: 1. In the second paragraph, the phrase "trailer vehicle safety" must be changed to "motor vehicle safety". A trailer is a motor vehicle under the National Traffic and Motor Vehicle Safety Act. 2. The letter is silent as to precautions the owner should take to reduce the chance that the malfunction will occur before the vehicle is repaired (@ 577.4(c) (4)). One obvious precaution where vehicle lighting is defective is to refrain from night operation. 3. The letter is silent as to an evaluation of the risk to traffic safety reasonably related to the defect (@ 577.4(d)). 4. We would consider the last paragraph on page 1 of your letter, reading, "The defect on those trailers . . . does not affect the mechanical operation of said trailer except insofar as the lighting is inefficient as installed according to the U.S. Department of Transportation," to be a disclaimer and prohibited by section 577.6. |
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ID: nht72-5.40OpenDATE: 03/30/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Truck Trailer Manufacturers Association TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of March 16, 1972, forwarding to us a draft of a TTMA Recommended Practice concerning GAWR and GVWR that you have developed as a guide for the truck trailer industry. You ask whether the draft is consistent with the applicable regulations (49 CFR Parts 567, 568). The draft which you submitted is consistent with the regulations although it is much more specific than the regulations and represents just one method of achieving compliance. We appreciate your efforts in making the substance of the regulations available to this large segment of the industry. |
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ID: nht73-1.1OpenDATE: 02/20/73 FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA TO: Joe Motley TITLE: FMVSS INTERPRETATION TEXT: March 28, 1973 Mr. Joe Motley 2704 Sparkman Drive, N. W. Huntsville, Alabama 35810 Dear Mr. Motley: This is in reply to your letter of December 15, 1972, regarding requirements applicable to manufacturers of ambulances. Ambulances are considered by NHTSA to be "multipurpose passenger vehicles", a vehicle type to which several Federal motor vehicle safety standards and regulations are applicable. Manufacturers of ambulances, including those who convert other vehicle types to ambulances, are required to manufacture each ambulance in accordance with those standards and regulations applicable to multipurpose passenger vehicles. The enclosed leaflet contains a short list and description of the standards and regulations, indicating which vehicle types are subject to each standard. The NHTSA is reponsible for both the promulgation and the enforcement of these standards. We rely on persons such as yourself to report possible violations of our requirements, and we appreciate your writing to us. I have referred your letter to our Office of Standards Enforcement, which will take steps to see that vehicles are manufactured in accordance with the Federal motor vehicle safety standards and other NHTSA regulations. Sincerely, Lawrence R. Schneider Chief Counsel |
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ID: nht94-9.4OpenTYPE: Interpretation-NHTSA DATE: January 11, 1994 FROM: Sam Nunn -- Committee on Armed Services, U.S. Senate TO: Jackie Lowey -- Acting Director of Congressional Affairs, U.S. Dept. of Transportation TITLE: None ATTACHMT: Attached to letter dated 2/8/94 from John Womack to Sam Nunn (A42; Part 571.7, letter dated 12/22/93 from Bill Lee to Sam Nunn, and letter dated 12/17/93 from Tim Adamson to Bill Lee TEXT: I recently received the enclosed inquiry from one of my constituents. Please review the matter thoroughly, in accordance with established policies and procedures, and provide me with a full report. I look forward to hearing from you in the very near future. |
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ID: nht94-1.19OpenTYPE: Interpretation-NHTSA DATE: January 11, 1994 FROM: Sam Nunn -- Committee on Armed Services, U.S. Senate TO: Jackie Lowey -- Acting Director of Congressional Affairs, U.S. Dept. of Transportation TITLE: None ATTACHMT: Attached to letter dated 2/8/94 from John Womack to Sam Nunn (A42; Part 571.7, letter dated 12/22/93 from Bill Lee to Sam Nunn, and letter dated 12/17/93 from Tim Adamson to Bill Lee TEXT: I recently received the enclosed inquiry from one of my constituents. Please review the matter thoroughly, in accordance with established policies and procedures, and provide me with a full report. I look forward to hearing from you in the very near future. |
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ID: Importhookup.2OpenMr. Tim Lau Dear Mr. Lau: This responds to your October 26, 2004 letter, in which you seek clarification regarding the permissibility of importing replaceable light sources for All Terrain Vehicles (ATVs). We are pleased to have the opportunity to respond to your inquiry. The National Highway Transportation Safety Administration (NHTSA) regulates "motor vehicles" and "motor vehicle equipment". "Motor vehicle" is defined by statute as "a vehicle driven or drawn by mechanical power and manufactured primarily for use on public streets, roads, and highways, but does not include a vehicle operated only on a rail line". 49 U.S.C. 30102(a)(6). NHTSA does not regulate vehicles manufactured primarily for off-road use (e.g., ATVs, snowmobiles, dirt bikes) nor the replacement equipment that is manufactured and sold specifically for those vehicles. Instead, the Consumer Product Safety Commission (CPSC) has jurisdiction over the safety of such items. With that said, there may also be State agencies that regulate this equipment, such as through State registration requirements for ATVs. We recommend that you consult with the relevant State authorities with responsibility for motor vehicles and motor vehicle equipment regarding any applicable requirements. If you have further questions, please feel free to contact Eric Stas of my staff at this address or by telephone at (202) 366-2992. Sincerely, Jacqueline Glassman ref:108 |
2005 |
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.