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: aiam2783OpenMr. Stan Haransky, Truck Body and Equipment Association, Inc., 5530 Wisconsin Avenue, Suite 1220, Washington, DC 20015; Mr. Stan Haransky Truck Body and Equipment Association Inc. 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Haransky: This responds to your February 21, 1978, letter asking whether sectio 567.5(c)(7) of Part 567, *Certification*, requires a manufacturer to use all of the described statements on its certification label.; The answer to your question is no. That section provides that th listed certification statements are to be used as appropriate. Therefore, it is anticipated that a manufacturer will select for inclusion on its certification labels only those certification statements in subparagraph (c)(7) that are appropriate for the certification of its vehicles.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2782OpenMr. Stan Haransky, Truck Body and Equipment Association, Inc., 5530 Wisconsin Avenue, Suite 1220, Washington, DC 20015; Mr. Stan Haransky Truck Body and Equipment Association Inc. 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Haransky: This responds to your February 21, 1978, letter asking whether sectio 567.5(c)(7) of Part 567, *Certification*, requires a manufacturer to use all of the described statements on its certification label.; The answer to your question is no. That section provides that th listed certification statements are to be used as appropriate. Therefore, it is anticipated that a manufacturer will select for inclusion on its certification labels only those certification statements in subparagraph (c)(7) that are appropriate for the certification of its vehicles.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3003OpenMr. Hisakazu Murakami, Nissan Motor Co., Ltd., P.O. Box 1606, Englewood Cliffs, New Jersey 07632; Mr. Hisakazu Murakami Nissan Motor Co. Ltd. P.O. Box 1606 Englewood Cliffs New Jersey 07632; Dear Mr. Murakami: I regret the delay in responding to your letter requesting a interpretation of Federal Motor Vehicle Safety Standard 127, *Speedometers and Odometers*. You asked whether the speedometer face you attached meets the requirements of the standard for the highlighting of the 55 mph on the speedometer face. The answer is 'yes.' The agency interprets 'highlight the number 55' to mean that manufacturers must make the number visually prominent relative to other numbers on the speedometer face. Nissan's speedometer face satisfies this interpretation.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam1543OpenMr. K. Nakajima, Director/General Manager, Factory Representative Office, Toyota Motor Sales, U.S.A. Inc., Lyndhurst Office Park, 1099 Wall Street, West, Lyndhurst, NJ 07071; Mr. K. Nakajima Director/General Manager Factory Representative Office Toyota Motor Sales U.S.A. Inc. Lyndhurst Office Park 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima: This is in reply to your letter of May 24, 1974 to Dr. Gregory askin whether the five master cylinder reservoir designs indicated would meet he requirements of S5.4.1 of Motor Vehicle Safety Standard No. 105-75.; Each of these designs appears to conform to S5.4.1 providing that th reservoir capacity requirements of S5.4.2 are met. It appears that Designs (3) and (4) would require additional fluid for the clutch.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0346OpenMr. Marvin S. Wright, Transportation and Distribution Department, Boise Cascade Corporation, P.O. Box 7757, Boise, ID 83707; Mr. Marvin S. Wright Transportation and Distribution Department Boise Cascade Corporation P.O. Box 7757 Boise ID 83707; Dear Mr. Wright: This is in reply to your letter of April 29, to Mr. Charles West, o the subject of air brake systems on mobile structure trailers. The standard to which you refer does not require air brakes to be installed on trailers, as your associates seem to fear. However, if your company decides on its own initiative to install air brakes on its mobile structure trailers, such brakes must conform to the air brake standard if the trailer is built on or after the effective date of the standard, January 1, 1973.; Please advise us if further clarification is needed. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam2014OpenG. Buzzi-Ferraris, Pirelli Tire Corporation, 600 Third Avenue, New York, N.Y. 10016; G. Buzzi-Ferraris Pirelli Tire Corporation 600 Third Avenue New York N.Y. 10016; Dear Mr. Buzzi-Ferraris: #Please forgive the delay in responding t your letter of May 5, 1975, which inquired about the permissibility of iron-branding the letters 'N.A.' on the sidewall of certain passenger car tires to indicate that they are not adjustable under your warranty. #Federal Motor Vehicle Safety Standard No. 109, *New Pneumatic Tires-Passenger Cars*, Specifies labeling and performance requirements for such tires. The NHTSA has no objection to the provision of additional labeling information such as the 'N.A.' which you have suggested. However, the tire must continue to be capable of meeting the standard's performance requirements at the completion of the hot-branding process. #Sincerely, Frank Berndt, Acting Chief Counsel; |
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ID: aiam1546OpenMr. K. Nakajima,Director/General Manager,Factory Representative Office,Toyota Motor Sales, U.S.A. Inc.,Lyndhurst Office Park,1099 Wall Street, West,Lyndhurst, New Jersey 07071; Mr. K. Nakajima Director/General Manager Factory Representative Office Toyota Motor Sales U.S.A. Inc. Lyndhurst Office Park 1099 Wall Street West Lyndhurst New Jersey 07071; Dear Mr. Nakajima:#This is in reply to your letter of May 24, 1974 t Dr. Gregory asking whether the five master Cylinder reservoir designs indicated would meet the requirements of S5.4.1 of Motor Vehicle Safety Standard No. 105-75.#Each of these designs appears to conform to S5.4.1 providing that the reservoir capacity requirements of S5.4.2 are met. It appears that Designs (3) and (4) would require additional fluid for the clutch.#Yours truly,Richard B. Dyson,Assistant Chief Counsel; |
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ID: aiam4335OpenMr. Joe Rutman, Travelite Division, Pathway, Ltd., Box 195, Grand Rapids, MI 49508; Mr. Joe Rutman Travelite Division Pathway Ltd. Box 195 Grand Rapids MI 49508; Dear Mr. Rutman: This is in reply to your letter of February 11, 1987, providin information about the electronic message display known as 'Tellite' which has been developed by Pathway Limited.; I enclosed copies of two recent agency interpretations on electroni message displays similar to yours. You will see that under Federal law such displays may not be used as original equipment, or as replacement equipment on passenger cars that carried center highmounted stop lamps as original equipment. Whether they are acceptable as aftermarket equipment on other vehicles depends on the laws of the individual States where the display will be sold and operated.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3115OpenMr. Ronald P. Mitchell, Executive Vice President, Phillips Motor Car Corporation, 1301 West Copan Road, Suite 3E, Pompano Beach, CA 33046; Mr. Ronald P. Mitchell Executive Vice President Phillips Motor Car Corporation 1301 West Copan Road Suite 3E Pompano Beach CA 33046; Dear Mr. Mitchell: This is in reply to your letter of September 22, 1979, asking whethe Phillips Motor Car Corporation is a 'manufacturer' or 'alterer' of the Berlina Coupe.; As you have described it, Phillips removes the body from a 198 Corvette, lengthens the frame and install (sic) newly manufactured body parts, retaining the interior safety features of the original vehicle.; It is clear from your description that Phillips alters previousl certified vehicles 'other than by the addition, substitution, or removal of readily attachable components such as mirrors or tires and rim assemblies ...' and is, therefore, subject to the certification requirements of Title 49, Code of Federal Regulations, Section 567.7. I enclose a copy of the regulation for your information and would be pleased to answer such further questions as you may have.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3114OpenMr. Ronald P. Mitchell, Executive Vice President, Phillips Motor Car Corporation, 1301 West Copan Road, Suite 3E, Pompano Beach, CA 33046; Mr. Ronald P. Mitchell Executive Vice President Phillips Motor Car Corporation 1301 West Copan Road Suite 3E Pompano Beach CA 33046; Dear Mr. Mitchell: This is in reply to your letter of September 22, 1979, asking whethe Phillips Motor Car Corporation is a 'manufacturer' or 'alterer' of the Berlina Coupe.; As you have described it, Phillips removes the body from a 198 Corvette, lengthens the frame and install (sic) newly manufactured body parts, retaining the interior safety features of the original vehicle.; It is clear from your description that Phillips alters previousl certified vehicles 'other than by the addition, substitution, or removal of readily attachable components such as mirrors or tires and rim assemblies ...' and is, therefore, subject to the certification requirements of Title 49, Code of Federal Regulations, Section 567.7. I enclose a copy of the regulation for your information and would be pleased to answer such further questions as you may have.; Sincerely, Frank Berndt, 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.