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: aiam0082OpenMr. D. S. Jarman, National Service Manager, Service Department, Volvo, Incorporated, Rockleigh, NJ 07647; Mr. D. S. Jarman National Service Manager Service Department Volvo Incorporated Rockleigh NJ 07647; Dear Mr. Jarman: Thank you for your letter of May 15, 1968, concerning electricall heated glass which you anticipate using for rear windows in your motor vehicles.; The present glazing requirement for motor vehicles are covered in Moto Vehicle Safety Standard No. 205, 'Glazing Materials.' Section S3, Requirements, stipulates that the glazing materials used must conform to U.S.A. Standard Z 26.1-1966, 'American Standard Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways,' July 15, 1966. If the electrically heated glass you mentioned meets the requirements of Standard No. 205, we would have no objection to its use.; Sincerely, George C. Nield, Acting Director, Motor Vehicle Safet Performance Service; |
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ID: aiam0664OpenMr. S. A. Heenan, Director, Research & Development, Stimsonite Division, Amerace - Esna Corporation, 3445 North Kimball Avenue, Chicago, IL 60618; Mr. S. A. Heenan Director Research & Development Stimsonite Division Amerace - Esna Corporation 3445 North Kimball Avenue Chicago IL 60618; Dear Mr. Heenan: In your letter of February 4 to Mr. Schneider you discussed difference between SAE Standard J594d, March 1967, *Reflex Reflectors,* and its successor J594e, March 1970. You asked 'whether relief can be granted from the unnecessary specular restriction appearing in Federal Motor Vehicle Safety Standard No. 108 because of its inclusion of J594d rather than J594e.'; We have reviewed your letter and the Administrator has determined tha the issue you raised merits initiation of rulemaking. I enclose a copy of a notice proposing an amendment to Standard No. 108 to substitute SAE J594e as the referenced requirement for reflex reflectors.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2588OpenMr. Joseph W. Kennebeck, Manager, Emissions, Safety and Development, Volkswagen of America, Inc., 818 Sylvan Avenue, Englewood Cliffs, N.J. 07632; Mr. Joseph W. Kennebeck Manager Emissions Safety and Development Volkswagen of America Inc. 818 Sylvan Avenue Englewood Cliffs N.J. 07632; Dear Mr. Kennebeck: This responds to Volkswagen's March 9, 1977, petition fo reconsideration of Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; Procedures for processing petitions for reconsideration are contains i the Code of Federal Regulations, Title 49, Part 553. Part 553.35(c) states that '[t]he Administrator does not consider repetitious petitions.' Your March 9 petitions raises two issues that were also discussed in your February 20, 1976, petition for reconsideration. The National Highway Traffic Safety Administration (NHTSA) carefully considered those issues in our February 7, 1977 (42 FR 7140) response to petitions for reconsideration. Since the Agency has considered these issues previously, the NHTSA declines to consider them again as you suggest.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam1452OpenMr. J.K. White,Domi Racer Distributors, inc.,5218 Wooster Road,Cincinnati, Ohio 45226; Mr. J.K. White Domi Racer Distributors inc. 5218 Wooster Road Cincinnati Ohio 45226; Dear Mr. White:#This responds to your March 19, 1974, request to kno if aircraft hydraulic hose is suitable for motor vehicle use under Standard 106, *Brake hoses*.#Standard No. 106, *Brake hoses*, presently applies to hydraulic brake hose for use in passenger cars, and therefore sale of aircraft hydraulic hose for use in motorcycles is presently legal. However, Standard 106 has been recently amended to require extensive performance testing and labeling of all motor vehicle brake hose manufactured after September 1, 1974. Sale of an aircraft hose manufactured after that date which has not been certified to conform to Standard 106 would violate S108 (a)(1) of the National Traffic and Motor Vehicle Safety Act of 1966. This means that the hose must be properly tested for conformity to the standard, and labeled according to the standard, before it can be sold as motor vehicle hose.#Yours truly,Richard B. Dyson,Assistant Chief Counsel; |
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ID: aiam1711OpenMr. William D. Stokes, Laurence, Stokes & Neilan, Suite 805, Crystal Plaza 1, 2001 Jefferson Davis Highway, Arlington, VA 22202; Mr. William D. Stokes Laurence Stokes & Neilan Suite 805 Crystal Plaza 1 2001 Jefferson Davis Highway Arlington VA 22202; Dear Mr. Stokes: This is in reply to your letter of November 8, 1974, asking whethe manufacturers of pickup caps are required to certify these equipment items under the National Traffic and Motor Vehicle Safety Act.; There is no requirement at present that pickup caps be certified. TH certification label is a manufacturer's representation that a motor vehicle or item of motor vehicle equipment conforms to all applicable Federal motor vehicle safety standards, and there are no standards that presently apply to pickup caps.; Your client should be aware of a related requirement. Motor Vehicl Safety Standard No. 205, 'Glazing materials' (49 CFR S571.205), specifies requirements for glazing materials (glass and plastics for windows, doors, and interior partitions) used in motor vehicles and motor vehicle equipment, including pickup covers (essentially pickup caps as you describe them). Although applicable to the glazing material, the standard's effect under the National Traffic and Motor Vehicle Safety Act is that pickup caps must contain only glazing materials that meet the requirements of the standard.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam1741OpenMs. Anita L. Mead, Secretary, Mead's East Side Wheel & Frame Co., P.O. Box 1367, Garden City, KS 67846; Ms. Anita L. Mead Secretary Mead's East Side Wheel & Frame Co. P.O. Box 1367 Garden City KS 67846; Dear Ms. Mead: This is in reply to your letter of December 6, 1974, asking whether yo must certify or recertify vehicles when you install new tag axles or extend truck frames, thereby changing the truck's gross vehicle weight rating.; NHTSA Certification regulations apply to manufacturers and alterers o new vehicles. A new vehicle is a vehicle which has not yet been sold to a user. If you perform these particular operations on new vehicles before they are 'completed' (49 CFR S568.3) and certified, and they are completed by you, then you will be responsible for certification. If you perform these operations on a new vehicle that has been completed and previously certified, then you will in all likelihood be a vehicle alterer, and subject to specific requirements applicable to alterers.; I have enclosed a copy of NHTSA's Certification regulations (49 CFR S 567,568) which contain the requirements for certification by manufacturers and alterers. Also enclosed is information on where you may obtain copies of other NHTSA standards and regulations. If you have further questions regarding these materials, please write to me.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam1712OpenMr. William D. Stokes, Laurence, Stokes & Neilan, Suite 805, Crystal Plaza 1, 2001 Jefferson Davis Highway, Arlington, VA 22202; Mr. William D. Stokes Laurence Stokes & Neilan Suite 805 Crystal Plaza 1 2001 Jefferson Davis Highway Arlington VA 22202; Dear Mr. Stokes: This is in reply to your letter of November 8, 1974, asking whethe manufacturers of pickup caps are required to certify these equipment items under the National Traffic and Motor Vehicle Safety Act.; There is no requirement at present that pickup caps be certified. Th certification label is a manufacturer's representation that a motor vehicle or item of motor vehicle equipment conforms to all applicable Federal motor vehicle safety standards, and there are no standards that presently apply to pickup caps.; Your client should be aware of a related requirement. Motor Vehicl Safety Standard No. 205, 'Glazing materials' (49 CFR S 571.205), specifies requirements for glazing materials (glass and plastics for windows, doors, and interior partitions) used in motor vehicles and motor vehicle equipment, including pickup covers (essentially pickup caps as you describe them). Although applicable to the glazing material, the standard's effect under the National Traffic and Motor Vehicle Safety Act is that pickup caps must contain only glazing materials that meet the requirements of the standard.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0395OpenMr. Keith D. Kroll, Director, Airstream Technical Center, 15939 Piuma Avenue, Cerritos, CA, 90701; Mr. Keith D. Kroll Director Airstream Technical Center 15939 Piuma Avenue Cerritos CA 90701; Dear Mr. Kroll: This is in response to your letter of June 25, 1971, to Mr. Douglas W Toms, Acting Administrator, National Highway Traffic Safety Administration, concerning lamp locations proposed for your 1972 Airstream trailer.; Federal Motor Vehicle Safety Standard No. 108, as amended October 31 1970 and February 3, 1971, effective January 1, 1972, requires that clearance lamps be mounted to indicate the overall width and as near the top as practicable. Paragraph S4.3.1.5 permits optional mounting height of rear clearance lamps when the rear identification lamps are mounted at the extreme height of a vehicle.; The front and rear clearance lamps mounted as shown on your drawin 10033, revision C, do not appear to meet these location requirements. These lamps could be mounted higher than shown and still indicate the overall width of the trailer at locations other than the upper right and left corners, perhaps as high as the front and rear windows.; In addition, the side reflex reflectors are to be located as far to th front and rear of the vehicle as practicable. Neither the front nor rear side reflex reflectors shown on the subject drawing appear to meet this requirement.; Sincerely, E. T. Driver, Director, Motor Vehicle Programs, Office o Operating Systems; |
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ID: aiam4253OpenMr. Donald J. Audia, 11843 Braesview No. 2412, San Antonio, TX 78213; Mr. Donald J. Audia 11843 Braesview No. 2412 San Antonio TX 78213; Dear Mr. Audia: This is in reply to your letter of December 12, 1986, to Taylor Vinso of this Office asking about the permissibility of manufacturing an aftermarket center highmounted stop lamp utilizing the colors yellow and orange, in addition to red, to signify 'the varying stages of a stopping car.'; Under Federal Motor Vehicle Safety Standard No. 108 *Lamps, Reflectiv Devices, and Associated Equipment* only the color red is permitted for original equipment center highmounted stop lamps, and for those aftermarket lamps manufactured to replace them. These lamps are generally found on passenger cars manufactured on and after September 1, 1985. Your planned device could not be manufactured and sold for this segment of the aftermarket since it does not conform to Standard No. 108. Further, a dealer, distributor, or motor vehicle repair business could not legally remove an original equipment center highmounted stop lamp and install your device. However, there is no Federal restriction on sale and installation of your device on passenger cars manufactured before September 1, 1985. The device would then be subject to the laws of any State where it would be sold or used. We regret that we are unable to advise you on these laws.; If you have any further questions we would be happy to answer them. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0427OpenMr. T. G. Burke, American Jawa Ltd., 185 Express Street, Plainview, LI, NY 11803; Mr. T. G. Burke American Jawa Ltd. 185 Express Street Plainview LI NY 11803; Dear Mr. Burke: This is in reply to your letter of August 17, 1971, inquiring whethe tires for use on racing motorcycles are subject to the Tire Identification and Record Keeping regulation (49 C.F.R. 574).; The regulation applies to 'manufacturers, . . . of new and retreade tires for use on motor vehicles' and, thus, whether the regulation applies to the tires in question depends on whether they are for use on a 'motor vehicle.' If the tires are for use on a racing motorcycle (i.e., a motorcycle which is not manufactured primarily for use on the public streets, roads, and highways), the tires are not considered to be manufactured for use on a 'motor vehicle' and the regulation does not apply to them. We consider a label such as 'For Racing Purposes Only, Not for Highway Use' as evidence of manufacture for off road use.; The execution of an HS-7 form is unnecessary when racing tires ar imported whether or not they are mounted on a racing motorcycle. However, should it be necessary to execute an HS-7 form to expedite importation, Box 8 should be used to indicate that the items being imported are not considered to be for use on a motor vehicle and are not items of motor vehicle equipment.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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.