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: aiam1077OpenMr. Guenter Storbeck, Product Planning Manager, Volkswagen of America, Inc., Englewood Cliffs, NJ 07632; Mr. Guenter Storbeck Product Planning Manager Volkswagen of America Inc. Englewood Cliffs NJ 07632; Dear Mr. Storbeck: This is in reply to your letter of April 2, 1973, regarding th classification of the Volkswagen Model 131 (The VW Thing) for purposes of the Federal Motor Vehicle Safety Standards.; Based on a review of your letter and its enclosures, we accept you classification of the Model 181 as a Multipurpose Passenger Vehicle.; Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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ID: aiam0858OpenMr. William E. McSherry, Product Manager, Panduit Corporation, 17301 Ridgeland Avenue, Tinley Park, IL, 60477; Mr. William E. McSherry Product Manager Panduit Corporation 17301 Ridgeland Avenue Tinley Park IL 60477; Dear Mr. McSherry: This is in reply to your letter of August 10, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', to the nylon cable ties you manufacture.; Paragraph S4.1 of the Standard does not include nylon cable ties o their equivalent and, accordingly, these components are not subject to the requirements of the Standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0306OpenMr. Paul Maloney, Elliot Business Machines, Randolph Industrial Park, Randolph, MA 02368; Mr. Paul Maloney Elliot Business Machines Randolph Industrial Park Randolph MA 02368; Dear Mr. Maloney: This is in reply to your letter of January 22, 1971, requesting that comment whether your system fulfills the requirements of Part 574, the Tire Identification and Record Keeping Regulation.; I am sure you will appreciate the fact that the Administration canno approve each of the various systems developed. Your system, upon a cursory review, appears adequate, however, the regulation speaks for itself concerning the actual requirements.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam0949OpenMr. Gene L. King, Mayfair Bedding Co., 2029 Alum Rock Avenue, San Jose, CA, 95116; Mr. Gene L. King Mayfair Bedding Co. 2029 Alum Rock Avenue San Jose CA 95116; Dear Mr. King: This is in reply to your letter of October 23, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', to house boats and tent camp trailers.; Standard No. 302 applies to passenger cars, multipurpose passenge vehicles, trucks, and buses. This does not include house boats or tent camp trailers.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0716OpenMr. John B. White, Engineering Manager, Michelin Tire Corporation - Technical Division, 2500 Marcus Avenue, Lake Success, New York 11040; Mr. John B. White Engineering Manager Michelin Tire Corporation - Technical Division 2500 Marcus Avenue Lake Success New York 11040; Dear Mr. White: #In reply to your letter of May 16, 1972, you interpretation is correct that paragraph S4.3.2 of Motor Vehicle Safety Standard No. 109 requires either the manufacturer's name and his assigned code number, or the brand name and the manufacturer's assigned number to be labeled onto the tire. The code number must appear in either case. #Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
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ID: aiam0721OpenMr. Leonardo Fioravanti, S.p.A. Carrozzeria Pininfarina, Casella Postale N. 295, 10100 Torino, Italy; Mr. Leonardo Fioravanti S.p.A. Carrozzeria Pininfarina Casella Postale N. 295 10100 Torino Italy; Dear Mr. Fioravanti: Thank you for your letter of May 25, 1972, inquiring about th applicability of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, and FMVSS No. 302, to the rear windows of convertible cars.; In FMVSS No. 302, the convertible top is not intended to refer to th rear window, but has reference only to the overhead material. Flammability of the transparent glazing material is regulated by FMVSS No. 205.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0935OpenMr. J. Patrick Roney, Hatch Imports, Inc., P. O. Box 413, Van Nuys, CA 91408; Mr. J. Patrick Roney Hatch Imports Inc. P. O. Box 413 Van Nuys CA 91408; Dear Mr. Roney: This is in reply to your letter of December 5, 1972, concernin approvals required by the Federal Government regarding the sale of safety glazing materials.; No approval by the Federal Government is required. Certification o conformance to Federal Motor Vehicle Safety Standard No. 205 and Section 114 of the National Traffic and Motor Vehicle Safety Act of 1966.; If you are not aware of State approvals, you may want to contact Mr Armand Cardarelli, of the American Association of Motor Vehicle Administrators, Suite 500, 1828 L Street, N.W., Washington, DC 20036; |
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ID: aiam4085OpenConfidential; Confidential; Dear Confidential: This is in response to your letter of June 21, 1985 requesting pursuant to 49 CFR Part 512, confidential treatment for your letter of that date and of the two attachments thereto.; Your request has been granted. NHTSA will treat your June 21, 198 letter and the attachments confidentially. Pursuant to a January 22, 1986 telephone conversation between (Confidential) and Heidi Lewis Coleman of my staff, our letter to you regarding this matter will be made publicly available to the extent indicated on the copy which is enclosed. Also enclosed is a copy of this confidentiality determination, which indicates the extent to which it will be made publicly available.; Sincerely, Kathleen DeMeter, Assistant Chief Counsel for General Law |
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ID: aiam0936OpenMr. J. Patrick Roney, Hatch Imports, Inc., P. O. Box 413, Van Nuys, CA 91408; Mr. J. Patrick Roney Hatch Imports Inc. P. O. Box 413 Van Nuys CA 91408; Dear Mr. Roney: This is in reply to your letter of December 5, 1972, concernin approvals required by the Federal Government regarding the sale of safety glazing materials.; No approval by the Federal Government is required. Certification o conformance to Federal Motor Vehicle Safety Standard No. 205 and Section 114 of the National Traffic and Motor Vehicle Safety Act of 1966.; If you are not aware of State approvals, you may want to contact Mr Armand Cardarelli, of the American Association of Motor Vehicle Administrators, Suite 500, 1828 L Street, N.W., Washington, DC 20036; |
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ID: aiam1331OpenMr. Adolph Kunasicwicz, 5644 Forest Avenue, Otter Lake, MI 48464; Mr. Adolph Kunasicwicz 5644 Forest Avenue Otter Lake MI 48464; Dear Mr. Kunasicwicz: Your request for information concerning the existence of penalties fo removal of the required certification label from a motor vehicle has been forwarded to us by the Federal Trade Commission.; The National Traffic and Motor Vehicle Safety Act requires that certification label, which under NHTSA regulations includes the name of the manufacturer and the date of manufacture, be permanently affixed to the motor vehicle. Although removal of this label does not carry a criminal penalty of either fine or imprisonment, a civil penalty of up to $1,000 is specified in certain situations.; Yours truly, Richard B. Dyson, Assistant 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.