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: aiam2609OpenMr. Byron A. Crampton, Manager of Engineering Services, Truck Body and Equipment Association, Inc., 5530 Wisconsin Avenue, N.W., Washington, DC 20015; Mr. Byron A. Crampton Manager of Engineering Services Truck Body and Equipment Association Inc. 5530 Wisconsin Avenue N.W. Washington DC 20015; Dear Mr. Crampton: This responds to your April 6, 1977, letter asking whether two propose labels satisfy the requirements for certification and information labels found in 49 CFR Part 567, *Certification*, and Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; The National Highway Traffic Safety Administration (NHTSA) does no issue advance approval of compliance by manufacturers with motor vehicle safety standards or regulations. The agency, however, will give an informal opinion as to whether your sample labels appear to comply with NHTSA regulations. From the illustrations you present, it appears that you have closely followed the format suggested in our regulations, and therefore, the labels seem to comply with the agency's requirements. Section S5.3(b) of Standard No. 120 permits the use of both labels when affixed in accordance with Part 567.4(b)- (f).; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3770OpenMr. Eddie Wayne, 4306 Emmit Drive, Erie, PA 16511; Mr. Eddie Wayne 4306 Emmit Drive Erie PA 16511; Dear Mr. Wayne: Thank you for your recent note asking if motorcycle headlamps could no be required to have a blue or green lens across the top portion, so that cycles could be distinguished from a four-wheeled motor vehicle with only one headlamp.; This is an interesting suggestion. However, we would not wish to impos a requirement that would interfere with the effectiveness of the single headlamp with which most motorcycles are equipped. The other side of the coin is marking the four- wheeled vehicle so that it is distinguishable from a motorcycle when one of its headlamps is out. We currently require passenger cars, light trucks, and others, to have amber or white parking lamps and amber front side marker lamps that are illuminated when the headlamps are on. While these lights may not be as readily visible from greater distances as a headlamp, nevertheless their presence on a vehicle does help to distinguish that vehicle from a motorcycle at night, when a headlamp is missing.; Thank you for your interest in safety. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2634OpenMr. Paul F. Bennett, Chief Engineer, Utility Trailer Manufacturing Co., P.O. Box 1299, City of Industry, California 91744; Mr. Paul F. Bennett Chief Engineer Utility Trailer Manufacturing Co. P.O. Box 1299 City of Industry California 91744; Dear Mr. Bennett: This responds to your May 20, 1977, letter asking whether your propose certification labels comply with the requirements of Part 567, *Certification*.; The National Highway Traffic Safety Administration (NHTSA) does no issue advance approval of compliance with Federal safety standards or regulations. We will, however, issue an opinion of whether your labels appear to comply with the regulations. The labels you submitted appear to comply with all but one of the requirements of Part 567 and Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*. On your certification labels, you list the symbol 'W/' before the rim information. This symbol should be dropped from the label. Further the rim size designation should use the symbol 'x' between the diameter and width. Information supplied on a certification label must be provided in the form detailed in Part 567.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3129OpenMr. H.A. Ritzenthaler, VDO-ARGO Instruments Inc., 980 Brooke Road, P.O. Box 2630, Winchester, Virginia 22601; Mr. H.A. Ritzenthaler VDO-ARGO Instruments Inc. 980 Brooke Road P.O. Box 2630 Winchester Virginia 22601; Dear Mr. Ritzenthaler: This is in response to your letter of January 25, 1979, in which yo stated your interpretation of Federal Motor Vehicle Safety Standard 127, *Speedometers and Odometers*, and asked that we advise you if action taken in accordance with this interpretation would place your company in violation of the standard. This letter is to confirm that your interpretation is correct.; According to your interpretation of Safety Standard 127, thos provisions which become effective for new motor vehicles on September 1, 1979 and September 1, 1980 are not applicable to speedometers and replacement parts produced for use in motor vehicles manufactured before those dates. This is correct because Safety Standard 127 is a vehicle standard and an equipment standard which applies to passenger cars, multipurpose passenger vehicles, trucks, motorcycles, and buses manufactured after the standard's effective dates and to speedometer and odometers for use in such vehicles. (Section 3, Safety Standard 127).; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4656OpenRobert N. Levin, Esq. Hudock & Levin 1101 Connecticut Avenue, NW Suite 910 Washington, DC 20036; Robert N. Levin Esq. Hudock & Levin 1101 Connecticut Avenue NW Suite 910 Washington DC 20036; "Dear Mr. Levin: This responds to your letter on behalf of one of you clients, seeking information on how our law and agency regulations might affect the installation of sun roofs in vehicles. You stated that your client is an automobile repair facility. According to your letter, you recently discovered this agency's regulation (49 CFR /567.7) requiring vehicle alterers to affix to the vehicles they alter a label certifying that the vehicle as altered continues to comply with all applicable safety standards. You asked whether such certification labels must be affixed by your client to those vehicles on which it installs a sun roof. I am pleased to have this opportunity to explain the requirements of our laws and regulations for you. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) authorizes this agency to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Two of those safety standards could be relevant to a repair shop's installation of sun roofs on motor vehicles. Standard No. 205, Glazing Materials, (49 CFR /571.205) sets performance requirements for glazing materials installed in new motor vehicles and for new glazing materials for use in motor vehicles. Any glazing incorporated in a vehicle's sun roof would have to conform to the applicable performance requirements set forth in Standard No. 205. In addition, installation of a sun roof could affect a vehicle's compliance with Standard No. 216, Roof Crush Resistance - Passenger Cars, (49 CFR 571.216), which sets forth strength requirements for roofs of passenger cars. Section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) specifies that, 'No person shall manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States, any motor vehicle or item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect under this title unless it is in conformity with such standard ...' Because of this statutory requirement, any person or business that installs sun roofs in new motor vehicles must certify that the vehicle continues to comply with the requirements of all applicable safety standards, including Standards No. 205 and 216. The form and contents for this certification are set forth in 49 CFR Part 567, Certification. Any manufacturer that installs a sun roof on a new motor vehicle is required by /567.4 or /567.5 to certify that the vehicle conforms to the requirements of all applicable safety standards. Any person or business that adds a sun roof to a previously certified new motor vehicle prior to its first sale for purposes other than resale would be required to certify the vehicle's continuing compliance with all applicable safety standards, in accordance with /567.7. Such a person or entity is an 'alterer' for the purposes of Part 567. (Persons or entities that modify vehicles by using a 'readily attachable component' or performing a 'minor finishing operation' are not considered 'alterers.' Modifications involving a readily attachable component or a minor finishing operation are instead subject to the requirements of 49 CFR /567.6. However, NHTSA does not consider a sun roof to be a 'readily attachable component' nor is the installation of a sun roof a 'minor finishing operation.' Hence, this exception is not relevant to your client's activities.). In addition to these certification requirements, an 'alterer' is considered a 'manufacturer' for the purposes of the Safety Act. Among other things, this means an alterer is responsible for notification and remedy of defects related to motor vehicle safety and noncompliances with applicable Federal motor vehicle safety standards arising from the alterations, as specified in sections 151-160 of the Safety Act (15 U.S.C 1411-1420). I have enclosed a general information sheet for new manufacturers that generally describes our statutory and regulatory requirements, and explains how to obtain copies of those statutes and regulations. The certification and labeling requirements set forth in section 114 of the Safety Act (15 U.S.C. 1403) and in Part 567 apply to vehicles only until the first sale of the vehicle for purposes other than resale. Thus, once a vehicle has been purchased by a consumer, persons that modify that vehicle for its owner (e.g., by installing a sun roof) are not required to certify or label the vehicle by this agency's statutes or regulations. A different statutory provision applies to modifications made by a repair shop to vehicles after the first purchase. Section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)) provides that, 'No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard, ...' To comply with the obligations imposed by this 'render inoperative' provision, your client should examine the sun roofs it installs and the means of installation for those sun roofs, and compare those with the requirements of Standards No. 205 and 216. After such an examination and comparison, your client should be able to decide if the sun roof installations it performs result in any apparent violations of the 'render inoperative' provision of the Safety Act. If your client decides there is no apparent 'render inoperative' violation, Federal law does not require any additional actions, such as labeling or certification, on your client's part in connection with the installation of sun roofs in vehicles after the first purchase of those vehicles. You should be aware that NHTSA may reexamine your client's decision and make its own determination of whether your client's sun roof installations may have violated the 'render inoperative' provision in the Safety Act in the context of an enforcement proceeding. I hope this information is helpful. If you have any additional questions, please feel free to contact Mr. Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosures"; |
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ID: aiam0418OpenMr. A.J. Macho, Holan Company, 4100 W. 150th Street, Cleveland, OH 44135; Mr. A.J. Macho Holan Company 4100 W. 150th Street Cleveland OH 44135; Dear Mr. Macho: This is in reply to your letters of June 30 and August 2 on the subjec of the applicability of Standard No. 210 to multipurpose passenger vehicles, trucks, and buses as amended by notice of March 4, 1971 (36 F.R. 4291). The standard applies to these vehicles effective July 1, 1971, even though the heading published in the *Register* refers only to passenger cars. The application of the standard is controlled by the application section, S2, and not by the heading of the standard. The heading only reflects the substance of the application section and should automatically change whenever the application is changed. Through oversight, the *Federal Register* was given no instructions as to heading changes, and therefore inserted the old heading into the March 4 notice. Since the heading has no substantive role, and since the amendment is only in effect until the revised Standard No. 210 becomes effective January 1, 1972, we have not requested the *Federal Register* to alter the heading.; I hope this is responsive to your question. Sincerely, Robert L. Carter, Acting Associate Administrator, Moto Vehicle Programs; |
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ID: aiam3729OpenMr. C. B. Bright, Jr., C. B. Bright Motor Co., Route 1, Ashland, MS 38603; Mr. C. B. Bright Jr. C. B. Bright Motor Co. Route 1 Ashland MS 38603; Dear Mr. Bright: This is in reply to your letter of July 19, 1983, to Mr. Vinson of thi office. You have asked whether you are violating any Federal standards or regulations by adding 'right side steering, accelerator, brakes & turn signal controls to rural mail carriers delivery vehicles (cars, pickup, jeeps, etc.).' You have told us that you do not modify in any way the left hand side controls with which the vehicle was originally equipped.; Assuming that your modifications do not affect the performance of an of the systems with which the vehicle was equipped by its original manufacturer, your conversion operations would not be prohibited by the National Traffic and Motor Vehicle Safety Act. However, with respect to any new vehicle that you modify which has not yet reached its first purchaser for purposes other than resale, you are required to affix a label identifying you as the alterer and certifying that the vehicle as altered meets all applicable Federal motor vehicle safety standards. This is required by Title 49 Code of Federal Regulations, Section 567.7. I enclose a copy of Part 567 for your information.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2322OpenMr. K. Nakajima, Director/General Manager, Factory Representative Office, Toyota Motor Sales, U.S.A., Inc., 1099 Wall Street, West Lyndhurst, New Jersey 07071; Mr. K. Nakajima Director/General Manager Factory Representative Office Toyota Motor Sales U.S.A. Inc. 1099 Wall Street West Lyndhurst New Jersey 07071; Dear Mr. Nakajima: This is in response to your February 23, 1976, letter concerning th rim marking requirements of S5.2 of Federal Motor Vehicle Safety Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; In its present form, S5.2 requires a rim to which the standard applie to be marked with its size designation and, if it is a multi-piece rim, its type designation as well. There is no prohibition on the marking of additional information beyond that which is required. Therefore, the marking of single piece rims with a type designation is permitted.; Please note that, in a notice published on Mary 6, 1976 (41 FR 18659 Docket No. 71-19, Notice 4), the National Highway Traffic Safety Administration delayed the effective dates of several of the standard's requirements. In particular, the effective date of S5.2, *Rim Marking*, was delayed until August 1, 1977. A copy of this notice is enclosed for your convenience.; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam3178OpenMr. Glen Brinks, 2110 Magnolia Avenue, Santa Ana, CA 92707; Mr. Glen Brinks 2110 Magnolia Avenue Santa Ana CA 92707; Dear Mr. Brinks: This responds to your recent letter requesting information concernin the Federal safety regulations applicable to motorcycle fuel tanks and motorcycle trailers.; The Federal Motor Vehicle Safety Standard regarding fuel syste integrity, Standard No. 301-75, currently does not apply to motorcycles. Two safety standards would be applicable to the manufacture of motorcycle trailers: Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment* and Safety Standard No. 120, *Tire Selection and Rims for Vehicles Other Than Passenger Cars*.; The manufacturer of a trailer, including a motorcycle trailer, woul have to certify the compliance of the trailer to these two safety standards. Part 566 of our regulations, *Manufacturer Identification* (49 CFR 566), specifies information which must be submitted to the NHTSA by manufacturers of motor vehicles, including trailers. Part 567, *Certification* (49 CFR 567), specifies the content and location of the certification label or tag that must be attached to motor vehicles regulated by our standards. I am enclosing an information sheet that explains where you can obtain copies of these safety standards and regulations.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0276OpenMr. Howard M. Rensin, Lesser & Leaser, Executive Building, 1030 - 15th Street, N. W., Washington, DC 20005; Mr. Howard M. Rensin Lesser & Leaser Executive Building 1030 - 15th Street N. W. Washington DC 20005; Dear Mr. Rensin: This is in reply to your letter of March 26, 1971, concernin regulations pertaining to automobile windshields.; Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials Passenger Cars, Multipurpose Passenger Vehicles, Motorcycles, Trucks and Buses*, a copy of which is enclosed, specifies the requirements of automotive glazing materials manufactured on or after January 1, 1968. ANSI Standard Z26.1- 1966, incorporated by reference, can be obtained from the American National Standards Institute, 1430 Broadway, New York, New York 10018, at a cost of $4.00.; The marking of the windshield that you depict in your letter of Marc 26 is not sufficient to identify its manufacturer. However, based on the '63' in the marking and the fact that the windshield shape fit the 1969 Plymouth, it can be hypothesized that the material in question is a laminated windshield of the improved design that has been used in 1966 and later models of U.S. automobiles.; There is not a requirement that windshields of this type completel shatter leaving no jagged fragments upon collision.; Sincerely, Clue D. Ferguson, Director, Office of Crashworthiness, Moto Vehicle Programs; |
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.