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: aiam4505OpenMr. M. Arisaka Manager, Automotive Lighting Homologation Sec. Stanley Electric Co. Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153 JAPAN; Mr. M. Arisaka Manager Automotive Lighting Homologation Sec. Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-ku Tokyo 153 JAPAN; Dear Mr. Arisaka: This is in reply to your letter of June l0, 1988 describing a 'flash to pass' headlighting feature and asking whether it is permissible under Federal Motor Vehicle Safety Standard No. 108. Enclosed is a copy of the agency's letter of June 17, 1987, to MMC Services, Inc. commenting on a similar device. The fact that Stanley's passing beam would project through an amber lens rather than a clear, or noncolored one, does not affect this interpretation. The address of the American Association of Motor Vehicle Administrators is now 4600 Wilson Boulevard, Arlington, Va. 33203. Sincerely, Erika Z. Jones Chief Counsel /Enclosure; |
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ID: aiam1405OpenJames B. Steward, Esq., Bridges and Collins, Bridges Building, 701 Teal Lake Avenue, Negaunee, MI 49866; James B. Steward Esq. Bridges and Collins Bridges Building 701 Teal Lake Avenue Negaunee MI 49866; Dear Mr. Steward: In reply to your request of January 30, 1974, I am enclosing a copy o the regulation issued to implement the odometer disclosure requirements of Public Law 92.513.; Although there are a variety of ways to determine whether a vehicle' actual mileage is greater than shown on the odometer, I know of only one method to establish the exact amount by which the indicated mileage has been exceeded: the testimony of a witness who knew the exact mileage on the car at the time the odometer was changed and who knows the accuracy of the odometer's performance after the change.; I would be most interested to learn of the progress of your action. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3261OpenMr. Karl-Heinz Ziwica, Manager, Safety & Emission Control Engineering, BMW of North America, Inc., Montvale, New Jersey 07645; Mr. Karl-Heinz Ziwica Manager Safety & Emission Control Engineering BMW of North America Inc. Montvale New Jersey 07645; Dear Mr. Ziwica: This responds to your letter of March 12, 1980. You asked whether, i the case of motorcycles, the appearance of the vehicle identification number (VIN) on the certification label required by 49 CFR Part 567 satisfies the requirements of S4.3 of Safety Standard No. 115 (49 CFR 571.115). The answer is yes. The Part 567 certification label meets the requirements of S4.3 regarding the use of labels. Please note that, in order to satisfy Safety Standard No. 115, the VIN on the certification label must meet the style requirements of S4.3.1.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0461OpenMr. Paul F. Bennett, Utility Trailer Manufacturing Company, P. O. Box 1299, City of Industry, CA, 91747; Mr. Paul F. Bennett Utility Trailer Manufacturing Company P. O. Box 1299 City of Industry CA 91747; Dear Mr. Bennett: Thank you for your letter of September 22 asking for clarification o the requirement for spacing of rear identification lamps on trailers, as applicable to your 'change number 21-23.'; Until January 1, 1972, Table II of Federal Motor Vehicle Safet Standard No. 108 requires that the three-lamp cluster be mounted 'as close as practicable to the vertical center line.' However, beginning January 1, 1972, the center lamp of the three-lamp cluster must be mounted on the vertical center line, and the offset arrangement in change number 21-23 will no longer meet the requirements of Standard No. 108.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam3170OpenMr. John F. Croonquist, President, Alternative Automotive, Inc., 999 N. Pacific Street, 33-D, Oceanside, CA 92054; Mr. John F. Croonquist President Alternative Automotive Inc. 999 N. Pacific Street 33-D Oceanside CA 92054; Dear Mr. Croonquist: This responds to your November 9, 1979, letter asking whether a vehicl that you plan to produce would be classified as a truck for purposes of applying the Federal motor vehicle safety standards.; In your letter, you state that your vehicle looks somewhat like a Jeep You state further that it is constructed on a Volkswagen truck chassis, carries two passengers, and is designed to transport property. As you know, the agency defines truck to be a vehicle that is designed primarily to transport property or speciality (sic) equipment. Since the vehicle that you plan to manufacture appears to be designed for the transportation of property and since it is constructed on a truck chassis, the agency concludes that it would be a truck for the purposes of applying the safety standards.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3167OpenMr. John F. Croonquist, President, Alternative Automotive, Inc., 999 N. Pacific Street, 33-D, Oceanside, CA 92054; Mr. John F. Croonquist President Alternative Automotive Inc. 999 N. Pacific Street 33-D Oceanside CA 92054; Dear Mr. Croonquist: This responds to your November 9, 1979, letter asking whether a vehicl that you plan to produce would be classified as a truck for purposes of applying the Federal motor vehicle safety standards.; In your letter, you state that your vehicle looks somewhat like a Jeep You state further that it is constructed on a Volkswagen truck chassis, carries two passengers, and is designed to transport property. As you know, the agency defines truck to be a vehicle that is designed primarily to transport property or speciality (sic) equipment. Since the vehicle that you plan to manufacture appears to be designed for the transportation of property and since it is constructed on a truck chassis, the agency concludes that it would be a truck for the purposes of applying the safety standards.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3997OpenMr. Rawleigh G. Decker, 18018 134 Avenue, Sun City West, AZ 85375; Mr. Rawleigh G. Decker 18018 134 Avenue Sun City West AZ 85375; Dear Mr. Decker: Thank you for your letter of July 23, 1985, to Secretary Dole, whic was referred to my office for reply. You expressed concern about conflicting state regulations on motor vehicle window tinting and asked about possible Federal regulations on this subject.; Congressman John McCain of Arizona has also recently written our agenc concerning conflicts in state tinting laws. I am enclosing a copy of the Administrator's letter of July 11, 1985, to Congressman McCain explaining what action the agency is taking on the subject of vehicle window tinting. I have also enclosed a (sic) information sheet which explains the Federal requirements on vehicle window tinting.; I hope this information is of assistance to you. If you have an further questions, please let me know.; Sincerely, Stephen P. Wood, Assistant Chief Counsel for Rulemaking |
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ID: aiam2778OpenMr. Greg Kreshel, Alloy Trailers, Inc., P.O. Box 19208, Spokane, WA 99219; Mr. Greg Kreshel Alloy Trailers Inc. P.O. Box 19208 Spokane WA 99219; Dear Mr. Kreshel: This responds to your February 10, 1978, question whether a trailer i considered newly manufactured under section 571.7(f) of NHTSA regulations if new materials are used except for four running gear assemblies that come from the front and rear of two wrecked trailers and are welded together to form the front and rear tandems of the reassembled full trailer.; It is our understanding that the axles, wheels, braking and suspensio components would be taken from the existing trailers, the identity of one of the existing trailers would be continued in the reassembled trailer, and the two existing trailers would be owned or leased by the user of the reassembled trailer. Assuming that this understanding of the facts is correct, the NHTSA would consider the reassembled trailer to be not newly manufactured under 49 CFR 571.7(f) for purposes of the Act, implementing regulations, and the safety standards.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0580OpenMr. Harold Visher, Vice President, Bandag Incorporated, 1055 Hershey Avenue, Muscatine, Iowa 52761; Mr. Harold Visher Vice President Bandag Incorporated 1055 Hershey Avenue Muscatine Iowa 52761; Dear Mr. Visher: #This is in reply to your letter of January 15, 1972 asking whether your 'treadless' passenger car tire will be considered a new tire under the Federal motor vehicle safety standard. You enclosed a diagram and explain that the 'treadless' tire is a 'brand new ... tire that we will furnish our dealers and then they will apply a new bandag tread to the tire and then sell the finished unit. #Based upon your description you have provided, we are of the opinion that you treadless tire is a new tire, and consequently subject to Motor Vehicle Safety Standard No. 109. Also, as each dealer applies the tread to the tire,each would be considered a 'manufacturer' under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 *et seq.*), and be responsible for the requirements imposed upon manufacturers by the Act, and the standards and regulations issued pursuant to it. #We are pleased to be of assistance. #Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
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ID: aiam0481OpenMr. K. L. Young, Specifications Analyst, The Flxible Company, Loudonville, OH, 44842; Mr. K. L. Young Specifications Analyst The Flxible Company Loudonville OH 44842; Dear Mr. Young: This is in reply to your letter of October 22 asking whether th 'hoodlum warning system' requested by the city of Boston (MBTA) would conform to Federal Motor Vehicle Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*.; Paragraph S3.5 of Standard No. 108 permits 'normally steadily-burnin lights [to] be capable of being individually flashed for signalling purposes' on motor vehicles manufactured before January 1, 1972. Therefore the hoodlum warning system is currently permissible under Standard No. 108.; However, a new requirement effective January 1, 1972, would prohibi the installation of this system on vehicles manufactured on or after this date. Paragraph S4.6 of Standard No. 108 states:; >>>'Where activated (a) Turn signal lamps, hazard warning signal lamps, and school bu warning lamps shall flash,; (b) *All other lamps shall be steady-burning* except that means may b provided to flash headlamps and side marker lamps for signalling purposes.' (emphasis added)<<<; Sincerely, Lawrence R. Schneider, 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.