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: nht93-2.22OpenDATE: March 21, 1993 FROM: Christopher Banner TO: John Wolmack (Womack) -- NHTSA TITLE: None ATTACHMT: Attached to letter dated 7-9-93 from John Womack to Christopher Banner (A41; Part 568; Part 571.7(e)) TEXT: I am looking into the possibility of producing a line of luxury cars and limousines based on an existing chassis but having a body of my own making. I am sure that the Department of Transportation has all sorts of safety and other regulations which would cover such a product. Representative Jim Slattery of Kansas recommended you as a source of information on this subject. Could you either send me relevant material, or direct me to a source? Here in Manhattan, we have a government documents section in the Kansas State University Library. Perhaps I could find the references of interest in it, if I knew what they were. |
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ID: nht95-4.93OpenTYPE: INTERPRETATION-NHTSA DATE: December 6, 1995 FROM: Alex Tartakovsky -- Sales, Marketing Dept., Unidex Group, Inc. TO: Office of Chief Council -- NHTSA TITLE: Any safety regulations regarding snow chains for motor vehicles. ATTACHMT: 1/29/96 letter from Samuel J. Dubbin to Alex Tartakovsky (A44; VSA 102) TEXT: I would like to request from you in writing any information regarding safety standards and/or laws covering snow chain use for roads and/or for motor vehicles. If there are no such standards please advise me so in writing. Please fax me back the above i nformation. Thank you! If you have any questions, or if I may assist you in any way please do not hesitate to call me at 708-299-0300. Best Regards, |
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ID: nht68-2.12OpenDATE: 06/03/68 FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA TO: Gruppe Autoelektrik TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letters of March 7 and May 15, 1968, to Mr. George C. Nield, concerning the requirements for motorcycle headlamps as specified in Motor Vehicle Safety Standard No. 108. On motorcycles, Standard No. 108 permits the use of unscaled headlamps conforming to SAE Standard J584. You will note that this SAE standard does not reference bulb sockets conforming to SAE Standard J567, which is intended to insure functional compatibility between bulb sockets and the bulbs listed in SAE Standard J573. Therefore, the bulbs used in motorcycle headlamps conforming to SAE Standard J584 need not conform to SAE Standard J573. Thank you for writing. |
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ID: nht95-1.21OpenTYPE: INTERPRETATION-NHTSA DATE: January 11, 1995 FROM: Philip R. Recht -- Chief Counsel, NHTSA TO: Mr. Michael A. Holmes -- Farmington Correctional Center TITLE: NONE ATTACHMT: Attached to 12/6/94 letter from Michael A. Holmes to Federico F. Pena (OCC 10596) TEXT: Dear Mr. Holmes: This responds to your letter of December 6, 1994, to the Secretary of Transportation, regarding the laws that apply to the manufacture of cars and light trucks. You have a design which you describe as "hydrogen turbine over electric." The principal law that the Department of Transportation administers that pertains to the construction of motor vehicles is Title 49 United States Code Chapter 301 - Motor Vehicle Safety. Under its authority, we have issued the Federal Motor Vehicle Safe ty Standards and other pertinent regulations. These are available from the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402 at an invoiced cost of around $ 25. The title of the volume you want is "49 CFR Parts 400-99 9"; all our regulations are in the 500 series. The Safety Standards are at Part 571. The applicability section of each standard informs the reader as to the types of vehicles to which it applies, such as passenger cars, motorcycles, etc. However, the standards don't differentiate between propulsion sources, and there are no standards that apply to "electric vehicles," or, in your case, "hydrogen turbine over electric." You should be aware that the Environmental Protection Agency establishes standards for motor vehicle emissions, and that the individual States are permitted to have their own standards in areas where the Department of Transportation has not acted, such a s horns and fog lamps. If you have any further questions, they should be directed to this Office and we will be pleased to answer them. Sincerely |
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ID: nht75-2.36OpenDATE: 10/30/75 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Willamette Wheel Inc. TITLE: FMVSR INTERPRETATION TEXT: This is in response to your letter of September 22, 1975, asking whether you are required to have a "manufacturers number" as a result of modification work you perform on Datsun pickups. It appears from your letter that you are a vehicle alterer as defined in 49 CFR 567.7 (copy enclosed). As an alterer, you are not necessarily a manufacturer and are not required to file the identifying information required by 49 CFR Part 566 (copy enclosed). However, as an alterer, you must affix a label to the vehicle stating that as altered, the vehicle conforms to applicable Federal motor vehicle safety standards. The label described in your letter does not meet the requirements of 49 CFR 567.7. If you have any further questions, please let us know. |
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ID: nht70-1.24OpenDATE: 04/17/70 FROM: Lawrence R. Schneider; NHTSA TO: Hans J. Loeffler TITLE: FMVSR INTERPRETATION TEXT: This is in response to our letter of April 5 and confirms your understanding that any Porsche automobile manufactured prior to January 1, 1968, need not confirm to Federal motor vehicle safety standards in order to be admitted into the United States. If you wish to import a vehicle manufactured prior to that date, you may be asked to execute Form Ne-7 (Importation of Motor Vehicles and Motor Vehicle Equipment Subject to Federal Motor Vehicle Safety Standards) at the port of entry. You should supply the vehicle data requested and check box 1, the declaration that "The merchandise was manufactured on a date when there was no Federal motor vehicle safety standard in effect which was applicable to it". I enclose a copy of this Form for your information. |
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ID: nht70-2.41OpenDATE: 12/10/70 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Kawasaki Motors Corporation TITLE: FMVSR INTERPRETATION TEXT: We have received your Petition for Reconsideration of Federal Motor Vehicle Safety Standard No. 108 (Lamps, Reflective Devices, and Associated Equipment), dated November 30 and air-mailed that date. To be considered as a petition for reconsideration our regulations (49 CFR @ 553.35(a)) require that a petition be "received not later than thirty (30) days after publication of the rule in the Federal Register". Because we did not receive your petition until the thirty-second day, @ 553.35(a) requires that it be treated as a petition for rule-making under @ 553.31. However, many of the questions you raise were also raised in the petition of the Motorcycle Industry Council, Inc. which was timely filed. You will hear in due course as to the disposition of your petition. |
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ID: nht72-2.31OpenDATE: 03/10/72 FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA TO: Strick Corp. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of February 21, 1972 asking for reconsideration of the opinion expressed in our letter of October 6, 1971, concerning the location of the rear identification lamp cluster on trailers of your manufacture. You are correct in saying that the requirement that Identification lamps be located" 'as close as practicable to the top of the vehicle' is subject to interpretation and individual judgment." We have expressed our opinion previously, and if you choose to mount your lights below the rear crossmember you should be prepared to demonstrate that this location is "as close as practicable to the top of the vehicle." I enclose a copy of a recent amendment to Standard No. 108 permitting off-center spacing of identification lamps. Perhaps this will alleviate your problem to come extent. |
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ID: nht71-5.17OpenDATE: 12/09/71 FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA TO: Import-Export TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of November 20, 1971, to Mr. Franklyn Bergsman, National Highway Traffic Safety Administration, concerning your "Flash Mirrors." As described in the documents you furnished to us, your "Flash Mirror" does not appear to impair the effectiveness of the required lighting equipment. If this is indeed the case, the use of your "Flash Mirrors" as original vehicle equipment is not prohibited by the Federal Motor Vehicle Safety Standard No. 108. Nor is there a Federal prohibition against sale of your device in the aftermarket; Standard No. 108 covers only specified replacement lighting equipment for vehicles manufactured on or after January 1, 1972. Since your product is not regulated by Standard 108, the sale and use of it is, however, subject to the regulations of the individual States. |
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ID: nht72-3.46OpenDATE: 03/17/72 FROM: J.E. LEYSATH FOR E.T. DRIVER -- NHTSA TO: U.M. Electrical Distributers Ltd. TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of March 6, 1972, concerning warning buzzers for the automobile industry. The National Highway Traffic Safety Administration has issued two safety standards which specify warning requirments. These requirements are given in Paragraph S4.4 of Standard 114 and Paragraph S7.3.1 of Standard 208. A copy of these two standards are enclosed for your review and further information. You will note that these standards do not stipulate minimum requirements for the warning devices, and, at the present time, we have no plans to specify such requirements. The data sheet, however, which you enclosed will be useful to us should we specify such requirements in future amendments to these standards. We appreciate your writing to us, and if we can be of any further service, please let us know. |
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.