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: aiam0822OpenMr. Thomas C. Morrill, Vice President, State Farm Mutual Automobile Insurance Company, Bloomington, IL 61701; Mr. Thomas C. Morrill Vice President State Farm Mutual Automobile Insurance Company Bloomington IL 61701; Dear Mr. Morrill: This is in further response to your letters of May 3 and August 8 1972, requesting that the NHTSA make available to insurance companies, such as State Farm, 'vehicle identification numbers' (VIN's) which the companies could then utilize to independently notify policyholders whose vehicles have been subject to manufacturers' defect notification campaigns.; The NHTSA has reconsidered your request and has determined to propose as an amendment to our Defect Reports regulations (49 CFR Part 573), that manufacturers be required to submit to the NHTSA the VIN's of vehicles subject to campaigns. The VIN's would be included in our public file and would be available to insurance companies and other groups who would wish to use them.; The NHTSA does not presently require manufacturers to submit the VIN' of campaigned vehicles (although the Defect Reports regulations do require manufacturers to compile the numbers for their own use). Because this will be a new requirement, the NHTSA is obligated by law to initiate rulemaking to provide for comments by interested persons, and to consider such comments in the decision as to whether the rule should be issued. We will take steps to publish the appropriate notice in the nearest possible future.; Your continuing interest in motor vehicle safety is, of course, greatl appreciated.; Sincerely, Douglas W. Toms, Administrator |
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ID: aiam3819OpenMs. Margaret Moore Oba, Hino Motors (U.S.A.) Inc., 200 Park Avenue, Suite 4114-12, New York, New York 10166; Ms. Margaret Moore Oba Hino Motors (U.S.A.) Inc. 200 Park Avenue Suite 4114-12 New York New York 10166; Dear Ms. Oba: This responds to your March 12, 1984 letter regarding the applicabilit of Federal Motor Vehicle Safety Standards to motor vehicles imported into Guam.; Under Sections 102(8), 102(9), and 108(a)(1)(A) of the National Traffi and Motor Vehicle Safety Act of 1966, 15 U.S.C. 1391(8), 1391(9), and 1397(a)(1)(A), motor vehicles introduced into commerce in Guam are subject to Federal Motor Vehicle Safety Standards. In general, the standards apply to the same extent to vehicles imported into Guam as to those imported into the continental U.S. However, as you note in you letter, FMVSS 103 (windshield defrosting and defogging systems) does not apply outside the continental U.S., as specified in section 3 of that standard. See 49 CFR 571.103. Other standards, such as FMVSS 124, which do not limit their applicability to specific geographic areas, apply fully in Guam. Therefore, vehicles imported into Guam must have an accelerator control system which returns the throttle to idle over a temperature range of -40 degrees F. to +125 degrees F.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3822OpenMs. Margaret Moore Oba, Hino Motors (U.S.A.) Inc., 200 Park Avenue, Suite 4114-12, New York, NY 10166; Ms. Margaret Moore Oba Hino Motors (U.S.A.) Inc. 200 Park Avenue Suite 4114-12 New York NY 10166; Dear Ms. Oba: This responds to your March 12, 1984 letter regarding the applicabilit of Federal Motor Vehicle Safety Standards to motor vehicles imported into Guam.; Under sections 102(8), 102(9), and 108(a)(1)(A) of the National Traffi and Motor Vehicle Safety Act of 1966, 15 U.S.C. 1391(8), 1391(9), and 1397(a)(1)(A), motor vehicles introduced into commerce in Guam are subject to Federal Motor Vehicle Safety Standards. In general, the standards apply to the same extent to vehicles imported into Guam as to those imported into the continental U.S. However, as you note in your letter, FMVSS 103 (windshield defrosting and defogging systems) does not apply outside the continental U.S., as specified in section 3 of that standard. See 49 CFR 571.103. Other standards, such as FMVSS 124, which do not limit their applicabilty to specific geographic areas, apply fully in Guam. Therefore, vehicles imported into Guam must have an accelerator control system which returns the throttle to idle over a temperature range of -40 degrees F. to +125 degrees F.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0952OpenMr. Richard H. Hardesty, III, Marketing Specialist-Lighting, Plastics Department, E. I. Dupont De Nemours & Company, Wilmington, DE, 19898; Mr. Richard H. Hardesty III Marketing Specialist-Lighting Plastics Department E. I. Dupont De Nemours & Company Wilmington DE 19898; Dear Mr. Hardesty: This is in reply to your letter of October 11, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials'. You ask whether the following components are subject to the requirements of the standard: horn buttons, decorative medallions, control knobs and handles, instrument dials and faces, break resistant mirrors, and lighting fixture lenses or diffusers.; The components that must meet the requirements of the standard ar listed in Paragraph S4.1. None of the components you have asked about are specifically listed in Paragraph S4.1, and normally will not be subject to the requirements. However, components may nevertheless be covered to the extent that they contain materials 'that are designed to absorb energy on contact by occupants in the event of a crash,' or to the extent that they form part of a component listed under Paragraph S4.1. For example, we might consider a decorative medallion that forms part of the surface of a front or side panel to be incorporated into the panel and therefore subject to the standard.; In answer to your request for 'the text of the proposed amendment...i preparation which will establish numerical size...and some information on when it will be incorporated into MVSS- 302.' I have no public information on this subject at this time.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2471OpenMr. Jack D. Cooper, President, Jack's Tire Company, Inc., U.S. Route 11, Edinburg, Virginia 22824; Mr. Jack D. Cooper President Jack's Tire Company Inc. U.S. Route 11 Edinburg Virginia 22824; Dear Mr. Cooper: This is in response to your November 23, 1976, letter concernin retreaded tires and Federal Motor Vehicle Safety Standard No. 117.; Your understanding that you are required to retain for three year certain records described in your letter is mistaken. While such a requirements was proposed in a Federal Register notice published on march 5, 1970 (35 FR 4136), if was never adopted. The NHTSA strongly recommends, however, that retreaders retain information on the materials and processes that they use, so that in the event of a defect or noncompliance they will be able to determine which tires are involved.; To assign you a retreader's identification mark, we need mor information from you. 49 CFR Part 574.6 specifies that:; >>>To obtain the identification mark required by S574.5(a), eac manufacturer of new or retreaded motor vehicle tires shall apply after November 30, 1970, in writing, to 'Tire Identification and Recordkeeping,' National Highway Traffic Safety Administration, 400 Seventh Street, S.W., Washington, D.C., 20590, identify himself as a manufacturer of new tires or retreaded tires, and furnish the following information:; (a) The name, or other designation identifying the applicant, and hi main office address.; (b) The name, or other identifying designation, of each individua plant operated by the manufacturer and the address of each plant, if applicable.; (c) The type of tires manufactured at each plant, e.g., passenger ca tires, bus tires, truck tires, motorcycle tires, or retreaded tires.<<<; Enclosed for your convenience is an information sheet entitled 'Wher to Obtain Motor Vehicle Safety Standards and Regulations.'; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam1593OpenMr K.W.Berner,Manager Component Design & Development,International Harvester,Truck Division Engineering,2911 Meyer Road,Fort Wayne,Indiana 46803; Mr K.W.Berner Manager Component Design & Development International Harvester Truck Division Engineering 2911 Meyer Road Fort Wayne Indiana 46803; Dear Mr. Berner:#This is in reply to your letter of August 13, 1974, t Dr. Gregory asking for confirmation of your interpretation of S5.3.1(b) of Motor Vehicle Safety Standard No. 105.#Paragraph S5.3.1(b) states that an indicator lamp shall be activated whenever there is ' drop in the level of brake fluid in a master cylinder reservoir to less than ... one-fourth of the fluid reservoir capacity in any reservoir compartment...' This will confirm that the lamp must activate whenever the fluid in any compartment is less then one-fourth the capacity of that compartment, rather than one-fourth the total capacity of the reservoir regardless of the number of compartments.#Yours truly, Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam1260OpenHonorable Dewey Bartlett, United States Senate, Washington, DC 20510; Honorable Dewey Bartlett United States Senate Washington DC 20510; Dear Senator Bartlett: This is in reply to your letter of July 23, 1973, forwarding to u correspondence from Mr. G. N. Nichols, President, Midwestern Products, Incorporated, Tulsa, concerning the applicability of Federal regulations to an air suspension auxiliary axle manufactured by Midwestern Products. According to the manufacturer's advertising brochure, this axle, the 'Micro-Air Retractable Safety Axle,' is intended to be used on pick-up and bobtail trucks, particularly in the recreational vehicle and related fields.; There are presently no Federal motor vehicle safety standards o regulations that apply to the manufacture of these axles. However, persons who install them on *new* pick-up trucks or other vehicle types (a 'new' vehicle under the National Traffic and Motor Vehicle Safety Act is one that has not yet been sold to a user) may be considered as vehicle alterers under provisions of NHTSA certification regulations which are to become effective February 1, 1974 (Docket No. 72-27, copy enclosed), and would be required to affix to the vehicle the label described in section 567.7 of those regulations.; Midwestern Products should be aware of these requirements whether i installs the Micro-Air axle or whether the installation is done by other parties. In the former case Midwestern would be responsible for affixing the required label, and in the latter it should provide the relevant information for the label regarding weight ratings to the party making the installation.; The NHTSA does not maintain a mailing list to provide copies of NHTS notices and regulations. Copies are available as indicated on the enclosed sheet, 'Where to Obtain Motor Vehicle Safety Standards and Regulations.'; We are pleased to be of assistance. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam1262OpenHonorable Dewey Bartlett, United States Senate, Washington, DC 20510; Honorable Dewey Bartlett United States Senate Washington DC 20510; Dear Senator Bartlett: This is in reply to your letter of July 23, 1973, forwarding to u correspondence from Mr. G. N. Nichols, President, Midwestern Products, Incorporated, Tulsa, concerning the applicability of Federal regulations to an air suspension auxiliary axle manufactured by Midwestern Products. According to the manufacturer's advertising brochure, this axle, the 'Micro-Air Retractable Safety Axle,' is intended to be used on pick-up and bobtail trucks, particularly in the recreational vehicle and related fields.; There are presently no Federal motor vehicle safety standards o regulations that apply to the manufacture of these axles. However, persons who install them on *new* pick-up trucks or other vehicle types (a 'new' vehicle under the National Traffic and Motor Vehicle Safety Act is one that has not yet been sold to a user) may be considered as vehicle alterers under provisions of NHTSA certification regulations which are to become effective February 1, 1974 (Docket No. 72-27, copy enclosed), and would be required to affix to the vehicle the label described in section 567.7 of those regulations.; Midwestern Products should be aware of these requirements whether i installs the Micro-Air axle or whether the installation is done by other parties. In the former case Midwestern would be responsible for affixing the required label, and in the latter it should provide the relevant information for the label regarding weight ratings to the party making the installation.; The NHTSA does not maintain a mailing list to provide copies of NHTS notices and regulations. Copies are available as indicated on the enclosed sheet, 'Where to Obtain Motor Vehicle Safety Standards and Regulations.'; We are pleased to be of assistance. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam1263OpenHonorable James R. Jones, House of Representatives, Washington, DC 20515; Honorable James R. Jones House of Representatives Washington DC 20515; Dear Mr. Jones: This is in reply to your letter of July 23, 1973, forwarding to u correspondence from Mr. G. N. Nichols, President, Midwestern Products, Incorporated, Tulsa, concerning the applicability of Federal regulations to an air suspension auxiliary axle manufactured by Midwestern Products. According to the manufacturer's advertising brochure, this axle, the 'Micro- Air Retractable Safety Axle,' is intended to be used on pick-up and bobtail trucks, particularly in the recreational vehicle and related fields.; There are presently no Federal motor vehicle safety standards o regulations that apply to the manufacture of these axles. However, persons who install them on *new* pick-up trucks or other vehicle types (a 'new vehicle under the National Traffic and Motor Vehicle Safety Act is one that has not yet been sold to a user) may be considered as vehicle alterers under provisions of NHTSA certification regulations which are to become effective February 1, 1974 (Docket No. 72-27, copy enclosed), and would be required to affix to the vehicle the label described in section 567.7 of those regulations.; Midwestern Products should be aware of these requirements whether i installs the Micro-Air axle or whether the installation is done by other parties. In the former case Midwestern would be responsible for affixing the required label, and in the latter it should provide the relevant information for the label regarding weight ratings to the party making the installation.; The NHTSA does not maintain a mailing list to provide copies of NHTS notices and regulations. Copies are available as indicated on the enclosed sheet, 'Where to Obtain Motor Vehicle sAfety Standards and Regulations.'; We are pleased to be of assistance. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam1261OpenHonorable James R. Jones, House of Representatives, Washington, DC 20515; Honorable James R. Jones House of Representatives Washington DC 20515; Dear Mr. Jones: This is in reply to your letter of July 23, 1973, forwarding to u correspondence from Mr. G. N. Nichols, President, Midwestern Products, Incorporated, Tulsa, concerning the applicability of Federal regulations to an air suspension auxiliary axle manufactured by Midwestern Products. According to the manufacturer's advertising brochure, this axle, the 'Micro- Air Retractable Safety Axle,' is intended to be used on pick-up and bobtail trucks, particularly in the recreational vehicle and related fields.; There are presently no Federal motor vehicle safety standards o regulations that apply to the manufacture of these axles. However, persons who install them on *new* pick-up trucks or other vehicle types (a 'new vehicle under the National Traffic and Motor Vehicle Safety Act is one that has not yet been sold to a user) may be considered as vehicle alterers under provisions of NHTSA certification regulations which are to become effective February 1, 1974 (Docket No. 72-27, copy enclosed), and would be required to affix to the vehicle the label described in section 567.7 of those regulations.; Midwestern Products should be aware of these requirements whether i installs the Micro-Air axle or whether the installation is done by other parties. In the former case Midwestern would be responsible for affixing the required label, and in the latter it should provide the relevant information for the label regarding weight ratings to the party making the installation.; The NHTSA does not maintain a mailing list to provide copies of NHTS notices and regulations. Copies are available as indicated on the enclosed sheet, 'Where to Obtain Motor Vehicle sAfety Standards and Regulations.'; We are pleased to be of assistance. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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.