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: nht93-6.4OpenDATE: August 9, 1993 FROM: Thomas Dougherty -- Research and Development, C.A.P.S. Inc. TO: John Womack -- Acting Chief Counsel, NHTSA TITLE: None ATTACHMT: Attached to letter dated 10/12/93 from John Womack to Thomas Dougherty (A41; VSA 102(4)) TEXT: I would like your opinion concerning any N.H.T.S.A. safety laws that might apply to our product as explained below. This product will be ready to sell to the general public in 30 to 60 days. Also, are there any labeling requirements? NAME OF PRODUCT: E.A.R.S. PURPOSE: To alert automobile drivers of an approaching emergency vehicle with siren activated. Our product can be used in all autos as an accessory. Drivers rendered hearing impaired because of sound-proofed autos as well as clinically hearing-impaired drivers will find our product very useful. PHYSICAL DESCRIPTION: The E.A.R.S. processor is about the size of a pack of cigarettes. It plugs into the cigarette lighter for its power source. A small LED light and an 82db tone alerts the driver of the approaching emergency vehicle. A weather-proofed microphone plugs into the back of the processor and is placed outside the auto, preferably on the roof or rear windshield. Our E.A.R.S. processor and microphone will be manufactured and tested in the United States. I would appreciate an answer from you as soon as possible. |
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ID: nht76-5.53OpenDATE: 04/12/76 FROM: STEPHEN P. WOOD FOR FRANK A. BERNDT -- NHTSA TO: Robert White TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of March 30, 1976, asking how United States importation regulations would affect your plan as a tourist to bring a 1964 Triumph motorcycle into the United States and to ride it to Mexico. There are no Federal safety standards that apply to a motorcycle manufactured before January 1, 1969. Should you wish to import a motorcycle manufactured after that date, as a non-resident of the United States you would be allowed to keep it here for a period of up to one year after entry with the understanding that it would not be sold. It is our understanding that the U.S. Environmental Protection Agency, the other Federal agency regulating importation of motor vehicles, has no current regulations for motorcycles. Brighton Sussex England 30.3.76 Dear Sir Please could you send me Details concerning any salter or other type of regulation governing the importation of motor bikes int. the U.S.A. I plan to take the bike through to Mexico (Illegible Words) be sold in the U.S. It is a 1964 Triumph 500U of standard construction. Your cooperation in this matter would be much appreciated Robert White |
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ID: nht91-7.46OpenDATE: December 13, 1991 FROM: Tony Llama -- President, Davenport Enterprises TO: Paul Jackson Rice -- Chief Counsel, NHTSA TITLE: None ATTACHMT: Attached to letter dated 01/03/92 from Paul Jackson Rice to Tony Llama (A39; Part 591) TEXT: We have a customer in Ecuador that assembles Fiat automobiles under a franchise from FIAT DO BRAZIL. They have contacted us for the purpose of designing and building an air conditioning unit for this vehicle. In order to do so, we must bring a car to the U.S.A. so that our engineers can work on it. By means of this letter, we would like to request from you prior written approval of vehicle admission to the U.S.A. for a period not exceeding 90 days, at which time it will be returned to Ecuador. This vehicle will come on a 20 foot container to our facilities in Dallas, Texas, and at no time will it be driven on the road. Upon completion of our work, it will also be returned on a 20 foot container. The specifications of this vehicle are as follows: Make: FIAT Motor No: 7575071 Model: PREMIO Chassis No: E-00091PI004 Engine: 1,600 cc Color: Blue One 1,100 cc engine will also be sent in a box inside the container, so we can design a compressor mount and drive kit for this engine, since this automobile will be equipped with either engine. This engine number is: 2764999. In order to speed up the paper work, we are enclosing copies of a previous request that was granted to us. In this case the vehicle was never sent due to problems beyond our control, so the forms were never used. Since there are other countries bidding for this business, time is of the essence. We would be very grateful if you could send us the authorization as soon as possible. |
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ID: nht73-2.37OpenDATE: 04/11/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Federal Trade Commission COPYEE: SUBJ. N40-30; CHRON N40-30; CHRON N40-10; MR. VINSON TITLE: FMVSR INTERPRETATION TEXT: This is in response to your letter of March 21, 1973, forwarding a complaint from Kenneth D. Peaslee. Mr. Peaslee ordered a 1973 Honda motorcycle, and was delivered one manufactured in December 1971. He asks if the dealer should make him a partial refund. The question is one that should be answered under Massachusetts laws and we are unable to advise him of his rights. There is no violation of any regulation administered by this agency. I note that the Massachusetts investigator made the statement in his letter of March 15, 1973, which you enclosed that the Federal Government "stopped" a practice of model year misdating "among foreign auto importers." That statement is not really accurate. We require (49 CFR Part 567) that each motor vehicle be equipped with a label disclosing, among other things, the month and year of manufacture. The main purpose of this is to allow a determination of what Federal motor vehicle safety standards were applicable when the vehicle was manufactured. This dating may make it commercially more difficult for a manufacturer or dealer to represent the vehicle as being of a later model year, but such representations are not prohibited or otherwise regulated under our rules. |
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ID: nht79-2.21OpenDATE: 08/31/79 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Halliburton Services TITLE: FMVSS INTERPRETATION TEXT: Mr. Ron Bechtel Halliburton Services Drawer 1431 Duncan, Oklahoma 73533 Dear Mr. Bechtel: This is in response to your letter of May 1, 1979, requesting an interpretation of the definition of "incomplete vehicle" contained in Federal Motor Vehicle Safety Standard No. 115, and in confirmation of your subsequent telephone conversations with Mr. Schwartz of my office. The term "incomplete vehicle" is defined in S3 of the standard to mean "an assemblage consisting, as a minimum, of frame and chassis structure, power train, steering system, suspension system, and braking system, to the extent that those systems are to be part of the completed vehicle, that requires further manufacturing operations, other than the addition of readily attachable components, such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, to become a completed trailer." You are correct in saying that most of the components listed in the definition are not meant to be part of a trailer. Consequently, an incomplete trailer would consist of only those components, such as a frame, listed in the definition which are meant to be part of the completed trailer. The outfitting of an incomplete trailer for a specific purpose would not be sufficient to make Halliburton Services responsible for assigning the vehicle identification number. Sincerely, Frank Berndt Chief Counsel (405) 251-3565 May 1, 1979 RB-90-79 Office of Chief Council National Highway Traffic Safety Administration 400 7th Street, S.W. Washington, D.C. 20590 Dear Sir: VIN Standards I would like to request an interpretation as to the definition of an "incomplete vehicle" in regard to trailers. The definition as contained in S571.115(s)(3) is only applicable to powered vehicles as the stated minimum requirements are not relative to trailers. Very truly yours, Ron Bechtel RB:im |
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ID: nht89-1.66OpenTYPE: INTERPRETATION-NHTSA DATE: 04/04/89 FROM: CARLOS CHAVEZ -- FHASA - WAGNER TO: NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 08/17/89 FROM STEPHEN P. WOOD -- NHTSA TO CARLOS CHAVEZ R -- FHASA-WAGNER; REDBOOK A34; PART 566 TEXT: Gentlemen: Our company FHASACV is manufacturing automotive parts as brake fluid, hydraulic brake rubber cups & boots, brake hose and flashers in Mexico. We would like to get a registration on U.S. DOT, but do not know which paper work and samples we must submitt with our application and also would like to get information on their cost. We know our products fill DOT requirements but anyway we would want to update our information on them. Please inform us the best way to obtain your last specs. Thanking in advance for your prompt repply. Sincerely, P.S. FHASA is a Licensee of Wagner Division Cooper Industries, Inc. |
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ID: 9889Open Herr Tilman Spingler Dear Mr. Spingler: This responds to your letter of March 25, 1994, asking for an interpretation of Motor Vehicle Safety Standard No. 108 with respect to integral beam headlighting systems. You reference a letter of this office to Toyota in which we permit location of the light source control module outside the headlamp housing but permanently attached to it by a cable. You have asked whether there are "requirements for this cable concerning indivisibility and integration . . . ." There are no such requirements for the cable in Standard No. 108, and the headlamp manufacturer may adopt the construction that it has determined is most suitable for its design. Sincerely,
John Womack Acting Chief Counsel ref:108 d:5/5/94
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1994 |
ID: nht69-1.3OpenDATE: 06/02/69 FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA TO: Hon. Jacob K. Javita -- U.S. Senate COPYEE: Mr. Delve; Mr. O'Mahoney TITLE: FMVSS INTERPRETATION TEXT: This is in further reply to your transmittal memorandum and attached letter from Mr. Robert W. Muller, New York, New York, inquiring about consumer information on passenger car tires. The Department of Transportation does not presently have a publication which would guide the consumer in selecting tires most suitable to his needs. To provide the consumer with an indication of the performance characteristics of tires, the Federal Highway Administration is obtaining research data and has established Docket 25, Uniform Tire Quality Grading System - Passenger Cars. A copy of the notice from the Federal Register is enclosed. As soon as a meaningful system of tire quality grading can be developed to assist the public, it will be made available. Enclosure |
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ID: nht68-3.30OpenDATE: 05/01/68 FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA TO: Truck Equipment, Incorporated TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of March 6, 1968, to Mr. Lowell K. Bridwell, Federal Highway Administrator, in which you inquired about certification responsibility for lighting on your truck bodies. Federal Motor Vehicle Safety Standard No. 108 on lighting applies to motor vehicles, not to motor vehicle equipment such as truck bodies. When the body is mounted on the chassis cab, the lighting requirements of Federal Standard No. 108, not certified by the manufacturer, must be fulfilled. Certification must be provided to the dealer when the chassis cab is completed for the dealer. A dealer selling to the final purchaser need not certify, but is responsible for lighting to be in compliance with Federal Standard No. 108, for that part of the lighting (or other standards) which have not been previously certified. Trusting this information answers your questions. |
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ID: nht72-2.33OpenDATE: 02/07/72 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: K-D Lamp Company TITLE: FMVSS INTERPRETATION TEXT: In your letter of January 20 to Mr. Vinson of this office you ask for an interpretation of paragraph S4.7 "Replacement Equipment" of Motor Vehicle Safety Standard No. 108. Standard No. 108 applies to motor vehicles manufactured on or after January 1, 1972. The standard specifies items with which these vehicles must be equipped. The standard also applies to items manufactured on or after January 1, 1972, intended to replace items required by Standard No. 108 to be original equipment on these vehicles. This replacement equipment must be manufactured to confirm to Standard No. 108 and certified as meeting all applicable Federal motor vehicle safety standards. The standard does not require conformance or certification of items intended as replacement equipment on vehicles manufactured before January 1, 1972. In this circumstance a manufacturer may continue to manufacture replacement equipment that does not meet Standard No. 108. |
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.