ID: nht95-3.2

TYPE: INTERPRETATION-NHTSA

DATE: June 7, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Douglas Helbig -- Vice President, Spencer Testing Services

TITLE: NONE

ATTACHMT: ATTACHED TO 5/17/95 LETTER FROM DOUGLAS C. HELBIG TO JOHN WOMACK

TEXT: Dear Mr. Helbig:

This responds to your letter asking me to confirm your belief that the National Highway Traffic Safety Administration (NHTSA) lacks the authority to require the periodic reinspection of Compressed Natural Gas (CNG) containers used as fuel tanks on altern ative fuel motor vehicles. You are correct. NHTSA has no authority to require the reinspection of motor vehicles or items of motor vehicle equipment.

Congress has authorized NHTSA to issue Federal motor vehicle safety standards (FMVSSs) for new motor vehicles and new items of motor vehicle equipment. The agency has used this authority to issue FMVSS No. 304, Compressed natural gas fuel container inte grity (49 CFR 571.304) which specifies requirements for the integrity of new CNG containers used to fuel motor vehicles. Each new CNG container manufactured on and after March 27, 1995 (the date the standard took effect) must comply with FMVSS No. 304 a nd be certified as complying with that standard when it is sold. However, after the first consumer purchase of a motor vehicle or an item of motor vehicle equipment, NHTSA's authority is much more limited and does not extend to the reinspection of motor vehicles or such equipment.

I wish to note that another agency of the U.S. Department of Transportation, the Research and Special Programs Administration (RSPA), is authorized by Congress to issue standards for containers, including CNG containers, used to transport hazardous mater ials. RSPA, however, does not have the statutory authority to regulate CNG containers that are used to fuel a motor vehicle. In other words, there are no Federal requirements applicable to the reinspection of CNG containers designed to fuel a motor veh icle.

I hope you find this information helpful. If you have any other questions, please contact Marvin Shaw at this address or by phone at (202) 366-2992.

ID: nht95-3.20

TYPE: INTERPRETATION-NHTSA

DATE: June 18, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: The Honorable Ken Calvert -- Member, United States House of Representatives

TITLE: NONE

ATTACHMT: ATTACHED TO 3/27/95 LETTER FROM KEN CALVERT TO EDWARD D. HARRILL

TEXT: Dear Mr. Calvert:

Thank you for your letter on behalf of your constituent, Mr. Alexander H. Patnode of Lake Elsinore, concerning an engine stand your constituent purchased from Pep Boys. Mr. Patnode asked for assistance after the engine stand caused the engine to fall, i njuring his ankle.

As explained below, the National Highway Traffic Safety Administration (NHTSA) considers the engine stand to be "motor vehicle equipment," subject to our regulation. NHTSA has authority to issue Federal motor vehicle safety standards for new motor vehic les and new items of motor vehicle equipment. 49 U.S.C. section 30102(a)(7) defines "motor vehicle equipment" in relevant part as:

(A) any system, part, or component of a motor vehicle as originally manufactured; (B) any similar part or component manufactured or sold for replacement or improvement of a system, part or component, or as an accessory, or addition to a motor vehicle . . . (emphasis added)

Although an engine stand is not a system, part, or component of a motor vehicle, it would be considered an "accessory" to a motor vehicle. NHTSA has typically used two criteria in determining whether a product is an "accessory." The first criterion is w hether a substantial portion of the expected use of the item is related to the operation or maintenance of motor vehicles. Expected use is determined by considering product advertising, product labeling, the type of store that sells the equipment, and i nformation about how the product is used. The second criterion is whether the product is intended to be purchased or otherwise acquired, and principally used by, ordinary users of motor vehicles. If a product satisfies both criteria, it is deemed an "acc essory."

We have determined the engine stand is an accessory, and thus an item of motor vehicle equipment. Applying the two criteria to the engine stand, (1) the engine stand is intended to be used in the maintenance of motor vehicle engines, and (2) assuming th e stand was new when sold to Mr. Patnode, it was intended to be acquired and used by ordinary users of motor vehicles.

We have searched our files by computer for reported complaints about engine stands, and for manufacturers' service bulletins and recalls. The search was conducted according to manufacturer (Rally) and equipment type (motor vehicle equipment: jacks, and other). A summary of the search results is enclosed. We found no reported instance of an injury caused by an engine stand, or of a manufacturer's issuing a service bulletin or recall because of an engine stand problem.

We will keep a copy of Mr. Patnode's letter in our files on reported complaints. In the future, the letter may be helpful in establishing a pattern of safety-related concerns caused by the type of engine stand that resulted in Mr. Patnode's injury.

I hope this information is helpful. If there are any questions, please let me know.

ID: nht95-3.21

TYPE: INTERPRETATION-NHTSA

DATE: June 19, 1995

FROM: Patrick M. Raher -- Hogan & Hartson

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: Re: Request For Interpretation - Seat Positioning Procedure Under FMVSS 208, 214

ATTACHMT: ATTACHED TO 8/31/95 LETTER FROM JOHN WOMACK TO PATRICK M. RAHER (A43; STD. 208)

TEXT: Dear Mr. Womack:

In the process of reviewing the requirements contained in the seat positioning procedures of FMVSS 208 and 214 for purposes of providing guidance to one of our clients, we noted that, depending on the interpretation of certain provisions, there is a p otential for as many as three different seating positions that could occur in a dynamic test. Such a situation is unacceptable from a certification and compliance standpoint. Accordingly, we are requesting an interpretation from your office.

FMVSS 208 (S8.1.2) and 214 (S 6.3) specify that "adjustable seats are in the adjustment position midway between the forward most and rear most positions, and if separately adjustable in the vertical direction, are at the lowest position." We have inte rpreted the foregoing to require that the midway point between a seat's maximum forward and maximum rearward position is the point at which the seat in its lowest configuration must be placed for purposes of testing. A question has arisen, however, with respect to power seats which have different maximum seating locations in the forward and rearward position depending on seat height. In such a situation the language of both standards could be interpreted to allow positioning of the seat at other than the true mid-point.

In order to provide you with an indication of the basis for this issue arising, we are enclosing three diagrams indicating driver seat ranges of motion for a power seat type assembly. These diagrams include step-by-step instructions on three possible interpretations of seat positions for adjustable seats prior to dynamic crash testing. We believe that since the seat positions described in all three operations vary because the seat position potential is trapezoidal rather than rectangular, due to th e mechanism utilized in the power seat operation, there are potentially different interpretations of the standards and, therefore, it is appropriate for your office to issue an interpretation clarifying this matter.

The impact of the three options is relatively clear. For example, when option 1 in the attachment is followed, the midway position of the seat is determined by

* raising the seat to its highest position and moving it forward, which is the farthest forward position;

* lowering the seat and moving it to its furthest rearward position; * finding the midway point of these two positions;

* moving the seat to midway position identified by the foregoing calculation

As you can see from Option 2 in the attachment, it is also possible to read the regulation to allow for the same forward and rearward reference points but to move the seat in its upward position to the mid-point and then lower the seat which, because of its mechanical operations, would actually move the seat back from the true midpoint of the seat travel line. Finally, Option 3 in the attachment could lead to a situation where the lowest seat position is used for identifying the forward and rearward most locations and identifying a midpoint. This, we believe is the most unlikely of all three interpretations because it fully ignores the most forward seating position.

In view of the importance of this interpretation to the issuance of proper legal advice under your regulations, we would very much appreciate a prompt interpretation of this question. We are, of course, fully prepared to meet with you or discuss the situation by telephone, to clarify any questions you may have and expedite issuance of a response to this request. We look forward to hearing from the Agency with respect to their interpretation of this matter.

Best regards.

ID: nht95-3.22

TYPE: INTERPRETATION-NHTSA

DATE: June 21, 1995

FROM: Tim L. Phillips -- International Tire Marketers

TO: Chief Counsel, NHTSA

TITLE: D.O.T. Tire Sizing Codes

ATTACHMT: ATTACHED TO 8/4/95 LETTER FROM JOHN WOMACK TO TIM PHILLIPS (A43; REDBOOK 2; PART 574)

TEXT: Chief Counsel,

Can you assist me in updating my information on new tire sizing codes used within the D.O.T. identification placed on tires? Please either fax me this information or mail it to my office at the address listed below.

Thank you for your assistance.

D.O.T. Sizing Codes Needed Passenger Light Truck Heavy Truck Small Industrial Construction

International Tire Marketers 358 W. Heber Street Glendora, California 91741 USA

Attachment

NHTSA DOCUMENT EXPLAINING THE IDENTIFICATION NUMBER FOR NEW TIRES. (OMITTED)

ID: nht95-3.23

TYPE: INTERPRETATION-NHTSA

DATE: June 22, 1995

FROM: Douglas Miyashiro -- ATTB System Engineering, Northrop Grumman

TO: Dorothy Nakama -- NHTSA

TITLE: Clarification of Title 49, Part 581

ATTACHMT: ATTACHED TO 7/13/95 LETTER FROM JOHN WOMACK TO DOUGLAS MIYASHIRO (A43; REDBOOK 2; PART 581)

TEXT: Dear Ms. Nakama,

Thank you for your recent help in providing clarification on a previous issue regarding the FMVSS title 49 part 571. Currently, our system engineering department is defining design requirement for the Northrop Grumman Advance Technology Transit Bus (ATT B) program working in conjunction with the Federal Transit Authority. We have been researching bumper safety standard concerning any applicable federal regulation for transit buses. Title 49, part 581 is the only reference on the subject of bumper stan dard and it states the following:

Title 49, Part 581.3 states, "This standards applies to passenger motor vehicles other than multipurpose passenger vehicle."

We are requesting clarification regarding the word "passenger motor vehicles." We feel that this pertains only to a passenger car but request clarification if a bus is inclusive in the definition of a "passenger motor vehicle." We have reviewed all the d efinitions listed in the FMVSS (title 49 part 571) for all different variation to the specific types of vehicle.

We would appreciate a written response clarifying the word "passenger motor vehicle" in order to determine what our design requirements are.

ID: nht95-3.24

TYPE: INTERPRETATION-NHTSA

DATE: June 23, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Richard Mark Gergel, Esq. -- Gergel, Burnette, Nickles, Grant & Leclair, P. A.

TITLE: NONE

ATTACHMT: ATTACHED TO 6/5/95 LETTER FROM RICHARD MARK GERGEL TO STEPHEN P. WOOD

TEXT: Dear Mr. Gergel:

We have received your letter of June 5, 1995, concerning "the applicability of the Motor Vehicle Safety Act to transactions between a local car dealer and purchasers within the same state." The litigation in which you are involved concerns the sale of a motor vehicle to a school to transport students. This vehicle, which had the capacity to carry more than 10 persons, "did not meet the safety standards for a 'school bus' under the Act." The defendant dealer asserts that a transaction between a dealer a nd purchaser within the same state is beyond the scope of the Act "since such a transaction allegedly is not within interstate commerce."

Taylor Vinson of this office talked with you on June 14 for a clarification of the facts. We understand that the vehicle in this case was a cargo van originally manufactured by Ford Motor Company and which, before its first purchase in good faith other than for resale, by a private school, was altered by persons not yet known to carry more than 10 persons. The vehicle does not appear to carry the certification of its alterer. The plaintiff in your case is the estate of a child killed while being tran sported in the vehicle. Under South Carolina law, failure to comply with a Federal safety statute is negligence per se. As noted above, the defendant dealer asserts that there is no violation of the Act because the sale of the vehicle did not occur in interstate commerce, and, hence, that it was not negligent per se.

This is our interpretation of the relevant portions of 49 U.S.C. Chapter 301 - Motor Vehicle Safety (formerly known as the National Traffic and Motor Vehicle Safety Act). Section 30112(a) provides as follows:

Except as provided in this section, sections 30113 and 30114 of this title, and subchapter III of this chapter, . . . a person may not manufacture for sale, sell, offer for sale, introduce or deliver for introduction in interstate commerce, or import int o the United States, any motor vehicle or item of motor vehicle equipment manufactured on or after the date an applicable motor vehicle safety standard prescribed under this chapter takes effect unless the vehicle or equipment complies with the standard and is covered by a certification issued under section 30115 of this title.

The sale or offer for sale of a nonconforming motor vehicle which is not certified as conforming to all applicable Federal motor vehicle safety standards is a violation of 49 U.S.C. 30112(a), regardless of whether the purchaser and seller reside in the s ame state. The phrase "introduce or deliver for introduction in interstate commerce" is self-contained and separated by commas from the rest of the prohibited acts. It in no way modifies the words "sell" and "offer for sale," which are violations separ ate and distinct from those of introducing or delivering for introduction in interstate commerce a noncomplying or uncertified motor vehicle. Thus, the case that you refer to, National Association of Motor Bus Owners v. Brinegar, 483 F.2d 1294 (D.C. Cir . 1973), is irrelevant to the issue of whether the dealer violated section 30112(a) by selling the vehicle in question.

As noted above, the statute provides certain exemptions and defenses that may be applicable to the question of whether there has been a violation of section 30112(a). The general and special exemptions of sections 30113 and 30114, and the import exempti ons of subchapter III are not relevant here. However, if the dealer can establish that any of the following defenses set out in section 30112(b) apply, there would be no violation.

* If the vehicle had previously been in use before it was sold to the school (section 30112(b)(1))

* If the dealer had no reason to know at the time it offered for sale and sold the vehicle to the private school, despite exercising reasonable care, that the van did not comply with Federal school bus safety standards. (section 30112(b)(2)(A))

* If the dealer held a certificate by the manufacturer stating that the vehicle complied with applicable Federal school bus safety standards, and did not know about the noncompliance before sale to the school. (section 30112(b)(2)(B))

Further, it appears that the alterer of this vehicle may have violated 49 CFR 568.8, a regulation issued under the authority of 49 U.S.C. 30115. Under this regulation, one who alters a certified vehicle before its first purchase in good faith for other than resale must affix its certification that the vehicle as altered complies with all applicable Federal motor vehicle safety standards.

If you have any further questions, please contact Taylor Vinson at (202) 366-5263.

ID: nht95-3.25

TYPE: INTERPRETATION-NHTSA

DATE: June 23, 1995

FROM: Yoshiaki Matsui -- Manager, Automotive Equipment, Legal & Homologation Section, Stanley Electric Co. Ltd.

TO: Chief Counsel, NHTSA

TITLE: Re.: Neon High Mounted Stop Lamps

ATTACHMT: ATTACHED TO 7/18/95 LETTER FROM JOHN WOMACK TO YOSHIAKI MATSUI. (REDBOOK 2; STD. 108)

TEXT: Dear Sir,

We are planning to develop high mounted stop lamps with neon tubes as their light sources.

During the last SAE meeting in Scottsdale, we heard Mr. van Iderstine mentioned that some new regulatory requirements should be provided for neon as light sources. However, we believe it is possible, even at this time, to conduct tests to such stop lamp s in accordance with FMVSS No. 108 and to determine the compliance of the tested high mounted stop lamps to FMVSS No. 108.

Therefore, we would like to ask you to give us your advice to the following questions concerning the acceptability of neon tubes as light sources.

Q1) Are neon tubes accepted as light sources by the current FMVSS No. 108?

Q2) If the answer to the above Q1) is NO, what kind of requirements should be provided to accept the neon?

Q3) If the ballast is integral and indivisible part of a neon high mounted stop lamp, like integral beam headlamps with HID, should such stop lamps be accepted under the current FMVSS No. 108 with no reservation provided the lamp is complied to all requi rements specified in the FMVSS No. 108?

Q4) If the ballast is separable from lamp assembly, should such high mounted stop lamps with neon tube be accepted under the current FMVSS No. 108 or under the amended FMVSS No. 108 allowing such stop lamps in near future?

Your answers will be highly appreciated.

ID: nht95-3.26

TYPE: INTERPRETATION-NHTSA

DATE: June 26, 1995

FROM: Jerel M. Sachs -- General Manager, Automotive Glass, Import Products Glass

TO: Clarke Harper

TITLE: NONE

ATTACHMT: ATTACHED TO 8/4/95 LETTER FROM JOHN WOMACK TO JEREL M. SACHS (A43; REDBOOK 2; STD. 205); ALSO ATTACHED TO 8/4/86 LETTER FROM ERIKA Z. JONES TO HENRY A. GORRY; ALSO ATTACHED TO 6/10/87 LETTER FROM ERIKA Z. JONES TO DAVID C. MAROON; ALSO ATTACHED TO 6/14/90 LETTER FROM PAUL JACKSON RICE TO NORMAND LAURENDEAU

TEXT: Dear Clark:

Thank you for returning my telephone call today. Pursuant to our telephone conversation I would like to state that Import Products Company is a prime glazing manufacturer and distributor. Our new address as of August 1st, 1995 will be; 55 Stockland Blv d., Bridgewater, MA 02324.

We intend to engage in the manufacture and/or contract manufacture of automotive safety glass in the United States and overseas. We are in the process of negotiations for the tooling and machinery of Lin's Glass Company who currently hold DOT # 396 and manufacture under the brand name of Sunmat. Part of the negotiation is acquiring the Sunmat brand name and corresponding DOT # 396.

I will contact you as soon as I know more about the release of the DOT # 396/ Sunmat name. In the meantime, please confirm acceptance of this letter but hold off assigning us a DOT number. Thank you for your help.

Enclosure (follow up letter)

July 13, 1995

Paul Atelsek Chief Council's Office 400 7 Street SW Washington, DC 20590

Dear Paul:

Per our telephone conversation yesterday 1 am faxing you a copy of the letter I sent to Clark Harper on June 26, 1995. As discussed, I see great merit for both NHTSA and our company in holding a D.O.T. number since we will be doing contract manufacturin g with a supplier who is also supplying other customers. This will help us monitor quality control and track our product in the marketplace.

Import Products Company has been in business for over 28 years and has been involved in the importing, contract manufacturing and distribution of automotive parts for use in the United States and export. We are experienced in doing voluntary recalls for quality control problems of automotive products that are unrelated to safety. I am sure that you must agree that NHTSA would have a much better chance working with IPG to implement a recall as compared to a company overseas in Taiwan, Malaysia or China through an Agent for Service of Process, which in many cases is a family relative or friend of somebody who works in the factory. Overall, I see this as a win-win combination for all of us and I hope you agree.

I look forward to hearing from you soon. Thank you.

Sincerely,

Jerel M. Sachs General Manager Automotive Glass, IMPORT PRODUCTS GLASS

cc: Clark Harper

ID: nht95-3.27

TYPE: INTERPRETATION-NHTSA

DATE: June 27, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: J. Gregory Studemeyer, Esq.

TITLE: NONE

ATTACHMT: ATTACHED TO 1/5/95 LETTER FROM J. GREGORY STUDEMEYER TO NHTSA (OCC 10647)

TEXT: Dear Mr. Studemeyer:

This responds to your letter of January 5, 1995, to this agency and your telephone conversation with Walter Myers of my staff on June 12, 1995, regarding the school bus standards we administer. You asked whether "your agency or any other federal agency notifies educational institutions of these [school bus] requirements."

The answer is no. The National Highway Traffic Safety Administration (NHTSA) does not maintain data on all schools or school districts throughout the nation, and does not routinely communicate with individual schools or school districts. The agency does , however, attend and disseminate information at school bus meetings and conferences nationwide and publishes all changes in school bus requirements in the Federal Register. In addition, NHTSA works closely and frequently with state directors of pupil t ransportation with regard to school transportation matters. In South Carolina, that official is the Director, Office of Transportation, Department of Education, 1429 Senate Street, Room 512, Columbia, SC 29201. Their telephone number is (803) 734-8244, and their fax number is (803) 734-8624.

Also for your information please find enclosed a fact sheet prepared by this office summarizing Federal school bus safety requirements. If you have any further questions or need additional information, please feel free to contact Walter Myers of my staf f at this address or at (202) 366-2992.

Enclosure

FEDERAL SCHOOL BUS SAFETY REQUIREMENTS

The National Highway Traffic Safety Administration (NHTSA) defines a bus as a motor vehicle designed to carry more than 10 persons, and a school bus as a bus that is sold or introduced into interstate commerce "for purposes that include carrying students to and from school or related events." Excluded are buses operated as common carriers in urban transportation. See 49 Code of Federal Regulations (CFR) 571.3.

In interpreting those provisions, NHTSA has looked to the nature of the particular institutions purchasing the buses. If the central purpose of the institution is the education of preprimary, primary, or secondary school students, including Head Start p articipants, whom NHTSA considers preprimary students, the buses must comply with all Federal motor vehicle safety standards (FMVSS) applicable to school buses. The FMVSSs are found in 49 CFR 571.101 through 571.304.

If, on the other hand, the institution is primarily custodial in nature, such as a nursery or day care center, or is concerned primarily with the education of post-secondary students such as college students, adult education or post-high school vocationa l students, the buses need not comply. Similarly, if transporting children to and from Sunday school or religious services, or if transporting athletic teams that have no connection to a school, the vehicles need not comply. However, if the vehicles ar e purchased to transport vocational students or athletic teams connected with preprimary, primary, or secondary schools or to transport students to or from such schools operated by a church, such as parochial schools, the vehicles would be required to co mply.

It is a violation of Federal law for any person knowingly to sell or lease as a school bus any new vehicle that does not comply with all FMVSSs applicable to school buses. The onus is on the seller or lessor to ascertain the intended use of the vehicle, and the seller/lessor is subject to substantial penalties for knowingly selling or leasing a noncomplying vehicle for use as a school bus, including civil fines and injunctive sanctions. These requirements do not apply to used vehicles.

Under Federal law, the purchaser or user of a vehicle is not under the same legal constraints as the seller. Since Federal law applies only to the manufacture and sale of new vehicles, a school may purchase and use any vehicle it chooses, whether new or used and without regard to whether it complies with Federal school bus standards, to transport its students. In addition, Federal law does not require the school to retrofit an existing vehicle to bring it into compliance with Federal standards. A sta te, however, may prescribe requirements relating to the use of school buses, including requirements for retrofitting or for operation and maintenance. The only Federal constraint on a state is that the state may not prescribe a standard for new vehicles covering the same aspect of performance as a Federal standard unless the state standard is identical to the Federal standard.

Finally, although not required by Federal law, NHTSA strongly recommends that only vehicles meeting Federal school bus safety standards be used to transport school children. See Highway Traffic Safety Program Guideline No. 17, Pupil Transportation Safet y, 23 CFR 1204. Further, NHTSA cautions that the use of vehicles that do not comply with Federal school bus safety standards to transport school children could result in increased liability in the event of an accident. That is a matter of state law, ho wever, so school districts should consult their attorneys and/or insurance carriers before transporting students in non-complying vehicles.

ID: nht95-3.28

TYPE: INTERPRETATION-NHTSA

DATE: June 27, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Thomas L. Wright, -- Acting Manager, MVS Customer Services, State of New Jersey, Department of Law and Public Safety, Division of Motor Vehicles

TITLE: NONE

ATTACHMT: ATTACHED TO 7/13/92 LETTER FROM PAUL JACKSON RICE TO JEFFREY PUENTES; ALSO ATTACHED TO 4/28/95 LETTER FROM THOMAS L. WRIGHT TO DOROTHY NAKAMA (OCC 10890)

TEXT: Dear Mr. Wright:

This responds to your request for information about responsibilities of motorcycle manufacturers. As you discussed with Dorothy Nakama, the National Highway Traffic Safety Administration (NHTSA) does not "regulate" how an enterprise becomes a "recognize d manufacturer."

Enclosed is NHTSA's information sheet for new manufacturers of motor vehicles and motor vehicle equipment, which discusses the main requirements of 49 U.S.C. section 30101 et seq. (formerly the Vehicle Safety Act). A copy of the Act is enclosed. Under section 30112(a) of the Act, a motorcycle manufacturer may not manufacture a motorcycle for sale unless the vehicle complies with all applicable Federal Motor Vehicle Safety Standards (FMVSS) and is covered by a certification issued under 49 U.S.C. secti on 30115. One safety standard is Standard No. 115 Vehicle Identification Number - Basic Requirements. (See 49 CFR 571.115.) In our regulations, at 49 CFR part 567 Certification, NHTSA has promulgated the requirement that a manufacturer certify complianc e of its motorcycle with all applicable safety standards. Under part 566, NHTSA requires manufacturers to submit certain identifying information and a description of the items they produce.

Also enclosed is a copy of a July 13, 1992 interpretation letter to Mr. Jeffrey Puentes, discussing serial numbers on motorcycle frames versus motorcycle VINs.

As you may be aware, "certificates of origin" are matters relating to vehicle titling, which the State regulates, rather than NHTSA.

I hope this information is helpful. If you have any further questions, please contact Ms. Nakama at (202) 366-2992.