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: nht71-2.31OpenDATE: 04/28/71 FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA TO: Toyota Motor Company, Ltd. TITLE: FMVSS INTERPRETATION TEXT: This is to conform your understanding that the DOT symbol, which represents the tire manufacturer's certification that the tire complies with the passenger car tire standard, is required on tires installed on multipurpose passenger vehicles, if such tires are originally designed and have passenger car tire size designations. However, since Standard No. 110 does not, at the present time, apply to multipurpose passenger vehicles, the responsibility for assuring that these tires contain the DOT symbol is limited to the tire manufacturer. |
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ID: nht90-1.65OpenTYPE: Interpretation-NHTSA DATE: March 8, 1990 FROM: Lloyd Bentsen -- U.S. Senator TO: Jerry Ralph Curry -- Administrator., NHTSA TITLE: None ATTACHMT: Attached to letter dated 5-25-90 To Lloyd Bentsen and From Stephen P. Wood; (A35; VSA 102(14), 108(a)(1)(a), 108(b)(1) ); Also attached to letter dated 2-12-90 To Lloyd Bentsen and From Johannah Bonewald; Also attached to letter To All Ford Ren t-A-Car System Members and From W.A. Jacques TEXT: I recently received the enclosed constituent inquiry, and I would very much appreciate your providing me with any pertinent information you might have regarding the matter. Your kind assistance is greatly appreciated. |
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ID: nht93-7.54OpenDATE: November 5, 1993 FROM: Terry Karas -- T.K. Auto Inc. TO: John Womack -- Acting Chief Council, NHTSA TITLE: None ATTACHMT: Attached to letter dated 1/21/94 from John Womack to Terry Karas (A42; Part 591) TEXT: I would like to know can a Canadian car that was accommodated by a Canadian manufacturing letter stating that the vehicle complies with U.S. safety standards, can be imported as a conforming vehicle under Box 2? If so, does it make a difference if it is being imported for commercial or private purposes. Your prompt response would be greatly appreciated. |
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ID: nht89-3.41OpenTYPE: INTERPRETATION-NHTSA DATE: NOVEMBER 21, 1989 FROM: MICHAEL S. KMIECIK TO: NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED APRIL 8, 1990 TO MICHAEL S. KMIECIK FROM STEPHEN P. WOOD; (A35; VSA 108(a)(2)(A); GRAPHICS OMITTED. TEXT: I would like to purchase several of these convertible kits and produce a few cars for resale. I need to know the safety standards that apply to convertibles 1978 and older. I would also request an interpretation as to whether this conversion kit meets these standards. The main safety features of this kit seem to be: 1. reinforce windshield pillar with steel. 2. 1 in. steel tubing welded to shock towers. 3. 2 x 3 x 1-1/2 in. channel iron over the original unibody frame rails. |
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ID: nht71-5.6OpenDATE: 11/22/71 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Trike Motor Company TITLE: FMVSR INTERPRETATION TEXT: You wrote some time ago to request information concerning the application of various motor vehicle safety standards to passenger cars with curb weights of less than 1,000 pounds. Contrary to the information you obtained from Motor Trend, this category of passenger cars is still exempt from the standards. There is a possibility that at some future date the exemption granted by 571.7(a) will be changed or revoked, but any such action can be taken only after opportunity for public comment. Please advise us if you feel it necessary to have your remaining questions answered. |
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ID: nht94-2.52OpenTYPE: INTERPRETATION-NHTSA DATE: April 20, 1994 FROM: Guy Dorleans -- Valeo Vision TO: Mike Perel-- NHTSA TITLE: None ATTACHMT: Attached To Letter Dated 6/6/94 From John Womack To Guy Dorleans (A42; Std. 108) TEXT: inner R or L incorporate HB3 bulbs (High beam) outer R or L incorporate HB4 bulbs (low beam) When the driver switches the Low beam on, outer HB4s only [Illegible Word] energized. When the driver switches the High Beam on, all 4 bulbs are energized together. We consider that outer unit must fulfill table 15a for Low Beam, an also that inner must fulfill with HB3 alone table 15a High beam. Could you confirm my interpretation? Best Regards. Fax 8011 33149426161 |
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ID: nht94-6.21OpenDATE: April 20, 1994 FROM: Guy Dorleans -- Valeo Vision TO: Mike Perel-- NHTSA TITLE: None ATTACHMT: Attached To Letter Dated 6/6/94 From John Womack To Guy Dorleans (A42; Std. 108) TEXT: inner R or L incorporate HB3 bulbs (High beam) outer R or L incorporate HB4 bulbs (low beam) When the driver switches the Low beam on, outer HB4s only [Illegible Word] energized. When the driver switches the High Beam on, all 4 bulbs are energized together. We consider that outer unit must fulfill table 15a for Low Beam, an also that inner must fulfill with HB3 alone table 15a High beam. Could you confirm my interpretation? Best Regards. Fax 8011 33149426161 |
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ID: nht94-3.24OpenTYPE: INTERPRETATION-NHTSA DATE: June 6, 1994 FROM: Walter Lavis TO: John Womack -- Acting Chief Counsel, NHTSA TITLE: NONE ATTACHMT: Attached to letter dated 7/7/94 from John Womack to Walter Lavis (A42; STD 108) TEXT: Enclosed are three proto-type samples of my safety reflectors along with my introduction literature. I spoke to Jim Gilkey and he referred me to you. My understanding is that using the standard DOT approved reflector tape would allow the use of my reflector for the trucking industry. I have approached several trucking companies and they liked the c oncept and asked if it was DOT approved. Therefore, this is the reason for my enquiry. Please advise if you have any further information regarding this matter. |
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ID: nht92-7.43OpenDATE: April 13, 1992 FROM: L.J. Sharman TO: NHTSA TITLE: None ATTACHMT: Attached to letter dated 8/12/92 from Paul J. Rice to L.J. Sharman (Redbook (2); VSA 108(b)(2)) TEXT: Motor Vehicle Safety Standard No. 302 details the procedure to be followed when testing the flammability of interior materials or cars etc. The Standard further states how to calculate the burn rate of the material under test. The Standard does not however indicate what information is to be recorded and how long the records must be kept. I am writing to enquire if NHTSA has published any such requirements or has any recommendations on what records are to be kept and for how long. Thank you for your assistance with this matter. |
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ID: nht88-2.98OpenTYPE: INTERPRETATION-NHTSA DATE: 08/11/88 FROM: ROBERT L. RIPLEY -- PRESIDENT KNAACK MANUFACTURING COMPANY TO: ERICA JONES -- OFFICE OF THE CHIEF COUNCIL NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 11/28/88 TO ROBERT L. RIPLEY FROM ERIKA Z. JONES, REDBOOK A32; STANDARD 556 TEXT: Dear Ms. Jones: I am enclosing copies of our three catalogs of products which we manufacture. I would appreciate it if you would review these catalogs and tell us whether we are required to file under Part 566, which requires motor vehicles and motor vehicle equipment manufacturers to supply NHTSA with information identifying themselves and describing products. I will await your reply. Thank you for your consideration. Sincerely, ENCLOSURE |
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.