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: nht72-3.17OpenDATE: 02/16/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Compact Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of December 29, 1971, concerning the use of glazing materials in the Kangaroo Camper which your company manufactures. You ask whether Motor Vehicle Safety Standard No. 205, "Glazing Materials" (49 CFR @ 571-205) applies to this item. Because it is impossible for a person to ride in the Kangaroo camper while the vehicle is in motion, we would not consider this item to be a "camper" within the meaning of Standard No. 205, and the standard does not apply to this product. |
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ID: nht72-2.32OpenDATE: 01/13/72 FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA TO: Joseph Lucas North America, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of December 23, 1971, to Mr. J. E. Leyseth of this Office in which you asked if each reflex area in a two-section reflector separated by a side marker lamp needs to meet the photometric requirements of a Class A reflector. Each reflex area need not meet the photometric requirements for a Class A reflex reflector provided that when the areas are combined they meet the photometric requirements, and provided further, that the marker lamp lens is included in the maximum exposed area of 12 sq. in. contained within a 7 in. diameter circle per SAE J594d. |
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ID: nht73-3.48OpenDATE: 04/03/73 FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA TO: The Flexible Co. TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of February 21, 1973, requesting that you be permitted to affix the Certification label for buses manufactured by your company on the right side of the dash panel, as illustrated in a picture (your serial #B72-4375-2) you have enclosed. As pictured, the label in the location you have chosen is easily readable without moving any part of the vehicle except an outer door, as required by section 567.4(c) of the Certification regulations, and your request that you be permitted to affix the label for these vehicles in that location is hereby approved. |
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ID: nht68-1.25OpenDATE: 04/18/68 FROM: William H. Risteen; NHTSA TO: Department of California Highway Patrol TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letters of February 15 and March 8, l968, concerning application of Federal Motor Vehicle Safety Standard Number 205. Glazing materials used in campers, pickup canopies, and covers must conform to the requirements of Federal Motor Vehicle Safety Standard Number 205. I am enclosing a copy of [Illegible Word] Ruling 68-1 published in the Federal Register, Volume 33, Number 59 on March 26, 1968, and a copy of the Federal Motor Vehicle Safety Standards (with Amendments and Interpretations through February 15, 1968). |
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ID: nht75-4.24OpenDATE: 07/22/75 FROM: AUTHOR UNAVAILABLE; J. C. Schultz; NHTSA TO: RVIA TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of May 22, 1975, in which you request an interpretation which excludes roof vent covers in recreational vehicles from the coverage of Motor Vehicle Safety Standard No. 205. The National Highway Traffic Safety Administration (NHTSA) has received an identical request from Richards, Watson, Dreyfuss & Gershon on behalf of Hehr International, Inc. In response to that request, we have determined that roof vent covers should be included within the scope of Standard No. 205, but also concur that roof vent covers manufactured by the injection molding process are not susceptible to testing under the procedures found in USAS Z26.1. Consequently, we intend to issue in the near future proposed rulemaking which would establish surrogate testing procedures for this type of roof vent cover. Until such time as the new procedure is adopted, it is the intention of the NHTSA to take no action against manufacturers who do not certify that their injection molded roof vent covers meet the requirements of Standard No. 205 which incorporate the requirements of USAS Z26.1. |
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ID: nht72-5.48OpenDATE: 11/08/72 FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA TO: Dalmon Enterprises Ltd. TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of September 20, 1972, in which you enclose a brochure describing your feed mover as requested by Mr. (Illegible Words), of my staff. In (Illegible Word) of the material submitted would seem to indicate that your classification of the land owner as farm machinery is valid. We would not, therefore, consider it to be a "motor vehicle" within the (Illegible Word) of the National Traffic and Motor Vehicle Safety Act (the Act) based on the information furnished. In addition to the Act (FL 87-563) and 49 C.F.R. 12.50, that you have requested, we are also enclosing Part 571 (formerly Part 371) of Title 49 of the Code of Federal Regulations. Of particular interest to you would be the interpretation on mini-bikes that set forth criteria to assist manufacturers in classifying their products insofar as off-road use is concerned. If you have further questions, we will be pleased to answer them. |
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ID: guam.ztvOpen Lt. James W. Cruz FAX (671) 475-6219 Dear Lt. Cruz: This is in reply to your fax of September 5, 2001, asking whether fog lamps made in Taiwan must comply with" Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, in order to be imported into Guam. A fog lamp is a "lamp" and not an item of "associated equipment." However, Standard No. 108 does not prescribe any requirements for fog, driving, and other aftermarket accessory lamps. Therefore, there are no requirements of this agency that they must meet in order to be imported into Guam. I hope that this answers your question. Sincerely, John Womack Ref:591 |
2001 |
ID: nht73-5.1OpenDATE: 08/28/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Florida Department of Agriculture & Consumer Services TITLE: FMVSR INTERPRETATION TEXT: This is in response to your request of July 18, 1973, that the National Highway Traffic Safety Administration undertake an investigation of possible odometer tampering on a vehicle purchased by Mr. Fulton Y. Roberts of Tallahassee. There are no criminal penalties for violation of the odometer requirements of the Motor Vehicle Information and Cost Savings Act. Remedies for violation of the odometer requirements are of two types. In the case of repeated violations, the United States Attorney may seek injunctive relief against further violations. In the case of a violation which has already occurred, the remedy is a private civil action by the defrauded party. For this reason, the NHTSA does not normally investigate incidents such as this. Mr. Roberts should be advised that he may be able to sue for $ 1,500 without proof of damages, or possibly more if he can prove damages. Mr. Roberts may wish to consult an attorney in this matter. The applicable provisions of the Act are enclosed. |
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ID: nht68-3.49OpenDATE: 08/05/68 FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA TO: Department of California Highway Patrol TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of July 1, 1968, to Mr. George C. Nield, concerning a clarification of paragraph S 3.4.3 of Federal Motor Vehicle Safety Standard No. 108. Paragraph S 3.4.3 specifies that, as a minimum, the taillamps shall be illuminated when the headlamps are illuminated, except when the headlamps are being flashed. The phrase "except when the headlamps are being flashed", permits the vehicle manufacturer to use a separate switch or flasher for illuminating the headlamps only when it would not be appropriate or in the interest of safety to simultaneously illuminate the taillamps and headlamps. In addition to the examples cited in your letter, such devices could also be used for flashing the headlamps on public transit vehicles to indicate an emergency situation. Since the subject matter of S 3.4.3 is taillamps and since Federal Standard No. 108 is otherwise silent as to headlamp flashing, this matter appears to be within the purview of the California vehicle code. Thank you for your continued interest in the motor vehicle safety standards. |
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ID: nht73-2.20OpenDATE: 12/22/73 FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA TO: American Safety Equipment Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in reference to our letter of August 20, 1973 (copy enclosed), requesting additional technical information on your harness release mechanism (the subject of your August 3, 1973, Petition for Rule Making). Please inform us within ten days whether or not you intend to furnish us the information we requested in our letter, so that we may make a final decision on your Petition for Rule Making action. |
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.