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: aiam0298OpenMr. J.T. Hite, III, President, Yarbrough Manufacturing Company, Inc., P.O. Box 848, 921 Mayfield Road, Arlington, TX 76010; Mr. J.T. Hite III President Yarbrough Manufacturing Company Inc. P.O. Box 848 921 Mayfield Road Arlington TX 76010; Dear Mr. Hite: This is in reply to your letter of January 21, 1971 concerning Tir Identification and Record Keeping regulations. Enclosed for your information is a copy of the Tire Identification and Record Keeping Regulation (49 CFR 574).; The regulation does not provide for exemptions or waivers, however, yo will note that under S 574.10 of the regulation vehicle manufacturers are required to keep records of tires on or in the vehicle when shipped to the dealer. Under the conditions you describe in your letter S 574.9(b) appears to be the relevant section and requires that the vehicle dealer record the name, address, etc. of the purchaser and forward this information to the tire manufacturer.; I hope this letter is responsive to the question you raise. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam3942OpenJohn D. Dusenbury, Esq., VP/Chief Counsel, United States Fleet Leasing, Inc., P.O. Box 5933, San Mateo, CA 94403; John D. Dusenbury Esq. VP/Chief Counsel United States Fleet Leasing Inc. P.O. Box 5933 San Mateo CA 94403; Dear Mr. Dusenbury: Thank you for your kind words in your letter of April 12, 1985. It i always gratifying to know that our efforts are appreciated.; *The Original Peck's Title Book* was recently revised. I have reviewe these revisions and it has become necessary to supplement the list set forth in my letter of April 9, 1985. The title documents of the following states may also be used in lieu of a separate odometer disclosure form if the purchaser completes all information concerning the application for title:; >>>Delaware, Maryland, Nebraska, Pennsylvania, Wyoming<<< Unless the application is completed, the title will not include th buyer's signature.; I remind you that if I can be of further assistance, do not hesitate t contact me.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam4138OpenMs. Cheryl Smith, B.B. Foreign Car Sales, 2983 El Camino Real, Santa Clara, CA 95051; Ms. Cheryl Smith B.B. Foreign Car Sales 2983 El Camino Real Santa Clara CA 95051; Dear Ms. Smith: Thank you for your recent telephone call requesting information on th Federal odometer law. Enclosed is a copy of Title IV of the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 1981 *et seq.*), which is the pertinent statute, as well as regulations prescribing odometer disclosure requirements (49 CFR Part 580), and a fact sheet that we have prepared on this subject.; Section 580.4 of the regulations prescribes the contents of th disclosure statement which must be furnished by the buyer to the seller at the time ownership of a motor vehicle is transferred. This includes the odometer reading at the time of transfer, the date of transfer, the name, address, and signature of both the buyer and seller, and a statement indicating either that the odometer reflects actual miles driven or that the true mileage is unknown.; You asked whether it is necessary for odometer disclosure statements t be furnished when ownership of a new vehicle is transferred. Under section 580.5(b) of the regulations, the odometer reading of a new vehicle need not be disclosed prior to its first transfer for any purposes other than resale. This exemption does not apply when ownership of the vehicle is transferred to the first retail customer. It is consequently necessary for your dealership to furnish odometer disclosure statements in transactions of this nature. As provided in section 580.7 of the regulations, it must furthermore retain a copy of these statements for a period of four years at its principal place of business in a manner that permits systematic retrieval.; I hope this information has been helpful. If we can be of any furthe assistance, please feel free to contact us again.; Sincerely, David W. Allen, Assistant Chief Counsel |
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ID: aiam0639OpenMr. Franklin E. de Luna, The Daystar Motor Homes, Inc., P.O. Box 20325, Los Angeles, CA 90006; Mr. Franklin E. de Luna The Daystar Motor Homes Inc. P.O. Box 20325 Los Angeles CA 90006; Dear Mr. de Luna: This is in reply to your letter of February 4 asking for copies o regulations applicable to a 'motor home' you wish to manufacture.; I enclose a copy of the National Traffic and Motor Vehicle Safety Ac of 1966, the basic statute setting forth your obligations as a manufacturer, and the authority for all applicable regulations. A publication titled 'Federal Motor Vehicle Safety Standard and Other Regulations' is available from the Superintendent of Documents, Government Printing Office, Washington, DC 20402. The price of $8.00 includes a subscription of up to one year of supplements. The Federal standards and regulations also appear in Title 49 of the Code of Federal Regulations (Title 19 for the importation regulations), generally available at law libraries. Amendments and proposals are published, when issued, in the *Federal Register*.; If you have any questions after obtaining and receiving these material I will be happy to answer them for you. A 'motor home' for your information, is defined as a 'multipurpose passenger vehicle' under the Federal standards.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4607OpenM. Iwase, General Manager Technical Information Dept. Koito Mfg. Co., Ltd. Shizuoka Works 500, Kitawaki Shimizu-shi, Shizuoka-ken Japan; M. Iwase General Manager Technical Information Dept. Koito Mfg. Co. Ltd. Shizuoka Works 500 Kitawaki Shimizu-shi Shizuoka-ken Japan; Dear Mr. Iwase: This is in reply to your letter of March 20, l989 asking for an interpretation of Motor Vehicle Safety Standard No. l08 as it applies to the location of the license plate lamp on motor vehicles. You noted the language in Tables II and IV of Standard No. l08 specifying that the lamp is to be located 'at rear license plate, to illuminate the plate from the top or sides,' for vehicles other than motorcycles. The requirement for motorcycles (Table IV) is simply that it be located 'at rear license plate.' You have asked for confirmation that, except on motorcycles, the license plate lamp shall not illuminate the plate from the bottom. Your interpretation is correct. The rationale for the requirement is that in a location other than at the bottom, the license plate lamp is less likely to be obstructed by snow or mud. I hope that this answers your question. Sincerely, Stephen P. Wood Acting Chief Counsel /; |
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ID: aiam1304OpenMrs. Joan Norton, 7741 Stilwell Road, Jacksonville, FL 32205; Mrs. Joan Norton 7741 Stilwell Road Jacksonville FL 32205; Dear Mrs. Norton: I appreciate your taking the time to bring to our attention possibl odometer tampering by Southside American, Inc., of Jacksonville, Florida.; The Motor Vehicle Information and Cost Savings Act prohibits odomete tampering and provides a remedy in the form of a civil action to be brought by a defrauded party. If it's possible to find the person who bought the car - a search that will probably require the assistance of the state motor vehicle department - he should be advised of the apparent error in the odometer. If he decides to pursue his remedy under the Act, he may have to rely heavily on your testimony, particularly if the oil sticker has been removed.; Although a private civil action is the principal remedy under the Act the Federal government has auxiliary authority to enjoin violations of the Act. You can assist us in the exercise of this authority by forwarding the enclosed copy of this letter to your local consumer affairs office. If they encounter additional instances of apparent violation by Southside, or by other dealers, we would consider the possibility of seeking an injunction.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3399OpenMarlin H. Dawdy, State Farm Mutual Automobile Insurance Co., Easter Office, 1500 State Farm Blvd., Charlottesville, VA 22909; Marlin H. Dawdy State Farm Mutual Automobile Insurance Co. Easter Office 1500 State Farm Blvd. Charlottesville VA 22909; Dear Mr. Dawdy: This is in response to your letter of April 17, 1981, asking whethe the Virginia Certificate of Title contains sufficient language in its odometer disclosure statement to serve as a substitute for the Federal Disclosure form.; The information on Virginia's revised title satisfies the requirement of the Federal odometer disclosure requirements and the title may be used in lieu of a separate form.; Sincerely, John Womack, Assistant Chief Counsel for General Law an Legislation; |
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ID: aiam2484OpenMr. P. J. Sandblade, Philsco Products Company, Inc., Post Office Box 317, Larned, KS 67550; Mr. P. J. Sandblade Philsco Products Company Inc. Post Office Box 317 Larned KS 67550; Dear Mr. Sandblade: This is in response to your December 27, 1976, letter concerning th effect of Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity, on the auxiliary fuel tanks that you manufacture for pick-up trucks. The question you have asked was addressed in my November 10, 1976, letter to Mr. Charles Atkinson. It does not appear that you are in danger of going out of the auxiliary tank business.; A copy of that letter is enclosed for your convenience. Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam1760OpenMr. Heinz W. Gerth, Assistant Vice President Engineering, Mercedes- Benz of North America, Inc., One Mercedes Drive, Montvale, NJ 07645; Mr. Heinz W. Gerth Assistant Vice President Engineering Mercedes- Benz of North America Inc. One Mercedes Drive Montvale NJ 07645; Dear Mr. Gerth: This is in response to your letter of December 4, 1974, inquirin whether the license plate mounting bracket and other associated hardware on the front end of the vehicle is covered under the proposed damage criteria of Part 581 and Standard No. 215.; The proposed Part 581 bumper standard (40 FR 10, January 2, 1975) which absorbs Standard No. 215, does not require the attachment of a license plate or equivalent substitute during the frontal pendulum test impacts. In addition, there are no damage criteria specified for license plates.; The proposal does, however, limit the amount of allowable damage to vehicle's exterior surfaces and does not specifically except from compliance, the portion of the vehicle that would serve as the place for license plate attachment. Vehicles manufactured from the date on which this proposal becomes effective until September 1, 1978, would, however, be permitted to incur surface damage to any component of the bumper system that contacts the impact ridge of the pendulum test device during testing. It seems likely that license plate mounting brackets would be located in an area that would be subject to this exception.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam4880OpenMs. Rosemary Dunlap President, Motor Voters l350 Beverly Road Suite ll5-240 Mclean, VA 22101; Ms. Rosemary Dunlap President Motor Voters l350 Beverly Road Suite ll5-240 Mclean VA 22101; Dear Ms. Dunlap: This responds to your letter concerning bills unde consideration by a number of states which would require disclosure concerning safety features in light trucks and vans and bumper strength. You stated that there is considerable debate about whether such bills would be preempted by Federal law, and noted that opponents have represented that a NHTSA spokesperson indicated that the states are preempted in this area. You stated that you have been unable to locate this statement, and asked whether NHTSA has an official opinion regarding Federal preemption and disclosure. I believe that the statement you refer to was made by NHTSA's Associate Administrator for Rulemaking, Barry Felrice, at the July l990 NHTSA Public/Industry Meeting. Mr. Felrice was responding to a question from the Center for Auto Safety. I have enclosed a copy of the relevant portion of the transcript for that meeting and the question. As you can see from the transcript, Mr. Felrice did not say that states are necessarily preempted from establishing information disclosure requirements. In order to provide an opinion as whether a particular bill would be preempted, I would need to review the specific language of the bill. I hope this information is helpful. Sincerely, Paul Jackson Rice Chief Counsel 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.